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GDV proposes reduction in bureaucracy

Last spring, Commission President Ursula von der Leyen announced the political goal of reducing 25% of all reporting requirements in the European Union. GDV participated in the EU Commission's Call for Evidence by making its own proposals.

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© Guillaume Perigois / Unsplash

The EU Commission wants to exempt the economy from reporting obligations.

In mid-October, the EU Commission presented initial proposals to reduce reporting requirements. These involved a shift in the sector-specific European Sustainability Reporting Standards (ESRS) and an "inflation adjustment" to the thresholds and size criteria for small and medium-sized enterprises, which are subject to lower standards for sustainability reporting. Jörg Asmussen, Chief Executive Officer of the German Insurance Association (GDV), commented: "These measures are at best initial approaches. The 25 percent target is nowhere near being achieved with these". Small and medium-sized enterprises in particular suffer from the excessive reporting requirements. "In sustainability reporting, the applicability of the thresholds for simplified reporting in the financial sector should be thoroughly reviewed. Until then, small and medium-sized insurers with up to 500 employees should be allowed to use the simplified reporting standards. These insurance undertakings are currently being treated like large corporations", Jörg Asmussen said.

The insurance industry is also calling for simplifications in the reporting on the Solvency II regulatory framework. For example, as part of the quarterly reports to supervisory authorities on their solvency situation, the reports for the fourth quarter could be omitted entirely. This is because just a few days after the fourth-quarter report, insurers have to submit a report for the year as a whole - which includes the status for the fourth quarter anyway. Next year's upcoming revision of the Delegated Regulation on Solvency II would be an appropriate occasion to remove this superfluous reporting requirement.

Insurers have been urging for some time now not to lose sight of the objective of the measures when introducing new reporting and administrative duties. "Otherwise, regulation - however well-intentioned it may be - will have no impact and will become a mere compliance duty for companies", Asmussen said.

In general, the insurance industry believes that the following should apply with respect to reporting requirements:

  • New reporting requirements should only be introduced if they are necessary.
  • Changes initiated by the supervisory authorities should also be reviewed and evaluated.
  • Overlap and duplication with other regulations should be avoided.
  • Proportionality should be anchored as a basic principle in all reporting requirements. Compared to large corporations, small enterprises with a small number of employees only have limited resources to meet reporting requirements.
  • Companies should be given sufficient time to adapt to new or changed reporting requirements.
  • Disclosure requirements should be reviewed in terms of their practicability and usefulness by means of consumer testing.

The full statement about the EU Commission's Call for Evidence can be found here:


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