We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Insurance Europe has communicated top-line support for many sustainable finance policies in Europe, but has cautioned against a prescriptive approach to regulatory intervention in this area.
Insurance Europe has stated support for the role of the finance industry in achieving the goals set out in the Paris Agreement. Insurance Europe has stated broad support for sustainable finance policy, but has often stressed that policy measures should also target the real economy.
In 2019, Insurance Europe cautiously supported policy to improve corporate ESG disclosure, specifying that such disclosure requirements should not be prescriptive. In 2020, Insurance Europe appeared to be supportive of the European Commission's review of the Non-Financial Reporting Directive (NFRD), supporting the need for increased standardization of non-financial information and the expansion of the scope to cover more companies.
In 2019, stated broad support for the taxonomy in its Annual Report but opposed more progressive amendments proposed by members of the European Parliament including expansion to cover environmentally harmful activities and the extension of the scope to all financial products. In feedback to the Commission’s Technical Expert Group (TEG) in 2019, Insurance Europe expressed concern that the taxonomy risks being too complex to implement in practice. In response to the Commission in 2020, it also argued that expansion of the taxonomy to cover environmentally harmful activities should not be a priority.
In 2019, Insurance Europe expressed support for the EU Green Bond Standard and, in feedback to the TEG and the Commission in 2020, it supported legislation to introduce a centralized accreditation regime for external green bond verifiers. Insurance Europe further stated support for the EU GBS in feedback to the Commission on its establishment in 2020. However, in a 2022 position paper, Insurance Europe appeared to advocate for the weakening of the EU GBS by proposing that the standard should take into account transitional efforts. In feedback to the European Commission’s Joint Research Centre (JRC) in 2021, Insurance Europe raised concerns that the EU Ecolabel was too stringent, stating that “virtually no insurer will be able to meet the criteria and obtain the Ecolabel for any product”.
In a 2020 consultation response to the Commission, Insurance Europe did not support incorporating adverse ESG impacts into fiduciary duty. In response to the ESA’s Sustainable Finance Disclosure Regulation (SFDR) consultation on investor ESG disclosure in 2020, Insurance Europe supported less prescriptive regulation and suggested a phased-in approach.
In feedback on the European Commission’s review of Solvency II in 2020, Insurance Europe did not support the Commission’s proposal to introduce changes to capital requirements based on green/environmentally harmful investments. Insurance Europe further suggested that numerous climate-related proposals, including climate scenario analysis, were of “low importance”.
Insurance Europe has a clear disclosure of its sustainable finance policy positions and its membership on its website.