Insurance Europe responses to the ESRS and Voluntary Standards consultations

On 3 June, Insurance Europe and the European Insurance CFO Forum responded to the European Commission consultation on the ESRS.

The insurance industry welcomes the clarifications on the concept of fair presentation, confirming its role as an overarching principle focused on relevance and proportionality. The confirmation that reliefs under ESRS 1 (7.3) will remain permanent provides important certainty and supports the simplification objective.

The new provision on materiality assessment for undertakings managing investments under certain conditions (ESRS 1 AR 17) is also a positive development, which better reflects the economic reality of fiduciary activities and helps ensure reporting remains focused on what falls within their decision-making.

The insurance industry proposes a limited number of targeted adjustments to improve the workability of the standards, while ensuring meaningful and proportionate reporting:

Anticipated financial effects: introduce a review clause in 2030 (instead of the temporary relief) to assess whether methodologies, data availability, and market practices have sufficiently matured to enable robust and comparable quantitative disclosures.

Information materiality: remove the reference to "informed assessments" from the definition, as it still raises questions regarding its scope and practical implications.

GHG emissions reliefs: delete the provisions excluding GHG emissions from the reliefs under para. 91, as this risks obscuring company-specific differences and reducing decision-usefulness for investors.

Regarding ongoing discussions between the European Commission and the ISSB on potential equivalence, we welcome efforts to improve compatibility between the standards. Achieving practical equivalence, would be particularly beneficial, especially for internationally active insurers. We therefore encourage continued dialogue between the Commission and the ISSB, with a view to enabling subsidiary exemptions for European undertakings operating in IFRS jurisdictions outside the EU.

Insurance Europe also responded to the consultation on Voluntary Standards (VS).

The insurance industry considers the VS essential to maintain access to ESG data, as many companies will fall outside the CSRD scope following the Omnibus. Insurers rely on reliable, comparable and decision-useful data for investments, risk management and regulatory disclosures. In this context, alignment with ESRS and consistency across frameworks are strongly welcomed.

However, further clarification is needed on the value chain cap to ensure that financial institutions can continue to obtain the data required for regulatory purposes. The proposed structure ("necessary", "if applicable", "voluntary", and sector-specific) is also welcome, but would benefit from clearer and more operational distinctions.

Finally, a purely minimal dataset would not be sufficient. More granular and standardised data is needed to meet financial sector needs (e.g. SFDR, EU Taxonomy). A slightly more robust dataset would reduce reliance on proxies and third-party estimates, thereby improving comparability and efficiency.