Sustainable Finance Lobbying Overview: Allianz appears to be highly engaged on sustainable finance policy, with mostly supportive positions.

Top-Line Messaging on Sustainable Finance Policy: Both Allianz and subsidiary Allianz Global Investors have stated support for the Paris Agreement and the net-zero by 2050 goal. Allianz is a founding member of the Net-Zero Asset Owner Alliance and has also been part of a number of investor initiatives throughout 2020-21 advocating for net-zero by 2050 directed to, for instance, the German Federal Government, world leaders and governments. In a 2020 op-ed, Allianz stated support for fundamental reform to the financial sector to achieve climate goals. In 2020, Allianz stated broad support for many policies in the EU's Sustainable Finance Action Plan, including the taxonomy, green bond standards, ESG benchmarks and corporate ESG disclosure, in its 2020 group sustainability report. However, there are examples of Allianz and its subsidiaries taking more cautious positions on certain sustainable finance policies in regulatory consultations.

Position on Regulated Corporate ESG Disclosure: In 2020, Allianz supported an ambitious update to the Non-Financial Reporting Directive to include mandatory climate-related disclosure, including transition targets. In a 2021 letter to the SEC, Allianz strongly advocated for regulated corporate ESG disclosure, calling for the development of a mandatory, globally harmonized standard with a double materiality perspective. After the SEC published its proposed rule in 2022, Allianz stated further support, including for mandatory disclosure of Scope 3 emissions.

However, in response to the UK’s FCA consultation on climate-related disclosures for asset manager and insurers in September 2021, Allianz Global Investors suggested a delayed timeline of implementation and argued that available data poses an issue for product and portfolio-level disclosures. Allianz also took a more cautious position on the European Sustainability Reporting Standards (ESRS) in response to the European Commission in 2022, highlighting the need for international standardization and a phased approach to implementation.

In December 2022, Allianz signed a joint statement calling for mandatory disclosure of nature-related impacts and dependencies.

Position on Taxonomies: In feedback to the European Commission on the Renewed Sustainable Finance Strategy in 2020, Allianz stated support for a full taxonomy that would cover both green and environmentally harmful activities, as well as in-between transition activities. Also in 2020, Allianz strongly supported a taxonomy with rigorous, science-based criteria in response to the Commission’s consultation on the taxonomy’s delegated acts. In 2022, Allianz signed a joint statement in favour of the development of a sustainable finance taxonomy in Australia. In a website article in July 2022, Allianz's representative on the EU's Platform on Sustainable Finance reiterated support for an extended taxonomy, as well as opposing the weakening of the 'green' criteria to include gas and nuclear activities.

Position on ESG Standards/Labels/Benchmarks: In response to the Commission in 2020, Allianz supported verification regulation of EU Green Bonds at the European level, however, it did oppose the need for minimum standard or labels for sustainably-denominated investment funds. It has also opposed the need for the EU to take action in creating an ESG benchmark. In 2022, Allianz Global Investors supported the UK’s proposed Sustainability Disclosure Requirements with minor exceptions, suggesting that the level of ambition for product levels should be determined by the client and not regulatory minimum requirements for asset allocation.

Position on Incorporating ESG Factors Into Investment Duties: In response to the Commission in 2020, Allianz was not supportive of further regulation to integrate adverse ESG impacts into fiduciary duties and advocated for a slow implementation of regulation around sustainability preferences of retail investors. In their 2020 sustainability reports, both Allianz and Allianz Global Investors also appeared to support the EU’s efforts on the Sustainable Finance Disclosure Regulation (SFDR).

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: In its 2022 Sustainability Report, Allianz states broad support for the “inclusion of sustainability in prudential regulation”.

Transparency: Allianz has some information on its engagement on public policy in its group sustainability report and on its website, as well as some information on sustainability-related industry associations memberships. Subsidiary Allianz Global Investors has stated that it engages with policymakers in line with the net-zero by 2050 goal, and has disclosed memberships to industry associations and activities and working groups it is part of, as well as board memberships.