Insurance Europe has published its response to a
consultation by the EC on its proposal for the establishment of a European
Single Access Point (ESAP), which it welcomes.
The ESAP will allow European insurers — which are Europe’s
largest institutional investors — to access robust, comparable and reliable
financial and ESG data in an electronic machine-readable format. This will help
insurers to steer their investment portfolios even more effectively towards
sustainability objectives, and to comply with disclosure requirements.
The insurance sector would, however, like to stress the
- The EC should develop an implementation roadmap specifying a
phased approach that gives priority to ESG data required under the Corporate
Sustainability Reporting Directive, the Sustainable Finance Disclosure
Regulation and the EU Taxonomy Regulation. Financial, prudential and other
types of information can be incorporated in later phases.
- Access for users, such as insurers, who require the ESAP
data to make sustainable investment decisions and to comply with regulatory
reporting requirements, should be free. A small fee to access and use ESAP data
would be acceptable, if it is deemed necessary to ensure the rapid development
of a well-functioning, reliable and user-friendly platform. However, such a fee
should be significantly lower than for data providers who will use the data as
part of their business model.
- The inclusion of information from packaged retail and
insurance-based investment products (PRIIPs) and pan-European Pensions Products
is premature. An assessment should be made, when the review of the PRIIPs
framework is finalised, to determine whether the revised PRIIPs key information
document is fit for purpose and whether the information should be included in
- Strong governance and expert input will be important for the
development of the ESAP to be a success. Insurers support the establishment of
an advisory steering board, composed of users, preparers, national and European
competent authorities to advise the European Securities and Markets Authority
on the set up and running of the ESAP.