Insurance Europe and the CFO Forum have responded to EIOPA’s consultation on the review of insurance disclosures under the Taxonomy Disclosures Delegated Act, launched as part of efforts to simplify and improve the framework.
In its response, insurers note that while the EU Taxonomy aims to improve transparency and support capital allocation towards environmentally sustainable economic activities, the current Underwriting KPI does not fulfil this objective in practice. Although insurers play an important role in enabling the transition and supporting climate adaptation through their core risk transfer function, the KPI does not provide a meaningful measure of this contribution and is generally not relied upon by investors when making investment decisions. This is because investors typically consider a broader range of sustainability information, much of which is already available through existing reporting frameworks, including sustainability disclosures under the Corporate Sustainability Reporting Directive (CSRD), transition plans and related narrative reporting.
Against this background, insurers support allowing reporting of the Underwriting KPI to be voluntary and at management’s discretion where the information is not considered relevant. This would represent a more proportionate approach while preserving the KPI where it remains relevant.
Insurance Europe and the CFO Forum also do not support the introduction of a Green Insured Activities (GIA) KPI, either as a complement to or a replacement for the current Underwriting KPI. The industry considers that introducing a new KPI would create significant additional reporting, governance and assurance requirements, while its relevance and decision-usefulness have not yet been demonstrated.
Finally, the industry emphasises that the simplification efforts currently being undertaken across the EU sustainable finance framework should be applied consistently. In particular, relevant simplification measures introduced under the revised European Sustainability Reporting Standards (ESRS) should also be reflected in the Taxonomy framework to improve coherence, reduce duplication and support a more proportionate reporting regime.