Positions

A proportionate, risk-based regulatory framework and realistic implementation timelines are essential to enable the responsible use of artificial intelligence without undermining Europe’s competitiveness and technological leadership. For insurance companies, legal certainty and practical feasibility are key prerequisites for innovation, effective risk management and consumer trust.

GDV welcomes the proposals in the Digital Omnibus, in particular the introduction of a clear legal basis for AI bias detection and mitigation under Article 4a and the removal of the registration requirement for non-high-risk AI systems under Article 6(3). These changes reduce legal uncertainty and fragmentation and support the compliant development and deployment of AI. The introduction of small mid-cap companies and the extension of SME exemptions are also positive steps; however, the corresponding thresholds should be raised in line with the Omnibus IV discussions to better reflect economic realities and strengthen competitiveness.

At the same time, the insurance industry remains cautious of classifying AI systems used for risk assessment and pricing in life and health insurance as high-risk and questions the feasibility of the proposed implementation timelines in the absence of standards and guidance. Further clarification is needed to ensure that established statistical methods, such as linear models and generalised linear models, are not classified as AI. 

Further information can be found here:

• Position Paper on the EU Commission Digital Package

Natural catastrophe (NatCat) insurance is vital for managing the financial impact of extreme weather events. It supports recovery, incentivizes risk prevention, and enables climate adaptation. As the EU advances climate resilience agenda, insurers play a key role in translating risk prevention into action.

GDV supports the European Integrated Framework for Climate Resilience proposed by the European Commission because it establishes a comprehensive, EU-wide legal basis for climate adaptation and risk management that is essential to maintain insurability, protect livelihoods and stabilise financial markets. The insurance industry seeks to drive prevention, transparency of risks, nature-based solutions and resilient infrastructure, and sees its role as a strategic partner in the implementation of adaptation strategies. We therefore call for the establishment of a European public natural hazard portal, legal construction bans in flood-prone areas, mandatory risk assessments for buildings, financial support for prevention and adaptation measures, and uniform EU-wide modelling and mapping of natural hazards. With this framework GDV aims to ensure that the transition to a resilient Europe is embedded into infrastructure, real estate, and financial markets, aligning risk management with sustainable investment and helping build climate-resilient environments.

Credit insurance protects businesses against payment defaults and insolvencies, supporting secure trade and investment. It is especially vital for SMEs and cross-border commerce. As the EU strengthens its Single Market and digital economy, credit insurance helps maintain liquidity and economic resilience.

The European Commission’s late payments proposal with a uniform 30-day payment deadline in business transactions could harm the European economy. Longer payment terms serve as an important financing tool, particularly for small and medium-sized enterprises, a rigid limit could lead to liquidity problems and higher insolvency risks. The proposal could weaken European companies’ competitiveness, as suppliers outside the EU would remain free to offer more flexible payment terms. GDV therefore recommends maintaining the current Late Payment Directive. 

Digitisation makes many things easier and faster. However, the obvious opportunities are also accompanied by an increasing number of risks for companies, public authorities as well as citizens. Cybercriminals and state-directed actors are active and tend to exploit existing security vulnerabilities in hardware and software. For insurance undertakings, the security and protection of customer data is essential. Consequently, high regulatory requirements exist, especially for information security. These must nevertheless be carefully balanced according to the actual risk situation and size of a company. This is necessary to ensure the highest possible level of security, but at the same time not to restrict a company's entrepreneurial and innovative power in a way that is detrimental to competition as a result of excessive bureaucracy. As part of the Critical Infrastructure, the insurance industry is proactively working to increase IT security and resilience. As early as 2010, the industry's own CERT, the Situation and Crisis Response Center for IT Security (LKRZV), was established as a preventive measure, rendering a valuable contribution to information security and resilience in close exchange with the Federal Office for Information Security (BSI).

The situation for cyber insurers in Germany has become significantly more challenging, with rising losses from hacker attacks nearly consuming premium income. Insurers now require effective cyber-security measures when issuing new policies, prevention must be treated as a serious responsibility, not an afterthought. A GDV survey among medium-sized companies revealed major gaps in basic IT security, making insurance coverage increasingly difficult to obtain. GDV urges businesses to strengthen their cyber defences, noting that insurance is important but cannot replace proper protection.

The Digital Operational Resilience Act (DORA) has been applicable since 17 January 2025. At the same time, BaFin repealed the Insurance Supervisory Requirements for IT (VAIT).

The aim of the Regulation is to strengthen the digital operational resilience of EU financial entities. To this end, regulated entities are required to put in place appropriate safeguards to mitigate cyberattacks and other risks. DORA establishes harmonised requirements for ICT risk management, incident reporting, system testing and oversight, as well as the management of third-party risks.

Through the Financial Market Digitalisation Act, the national legislator has additionally extended the scope of application of DORA to insurance holding companies and introduced far-reaching DORA-related audit requirements as part of the statutory annual financial statement audit. These requirements go beyond the European framework and place an additional burden on German insurance companies. 

Under the Digital Omnibus, the proposal allows data owners to refuse the disclosure of trade secrets where there is a high risk of unlawful acquisition, use, or disclosure to third countries or entities subject to weaker legal safeguards. However, the vague concepts of “high risk” and “unlawful acquisition” create legal uncertainty in practice. In the insurance industry’s view, the existing provision in Article 4(8) already provides sufficient clarity and adequately protects data owners’ interests in relation to trade secrets.

To remain competitive and deliver tangible benefits to citizens, the EU needs a GDPR framework that effectively protects privacy while enabling innovation. For consumers, this means faster claims handling, fairer pricing and improved fraud prevention; for society, it strengthens trust in digital services and the responsible use of AI. For European businesses, legal certainty and reduced compliance burdens are essential to allow investment in innovation rather than bureaucracy.

GDV welcomes the proposed modernisation of the GDPR under the Digital Omnibus, including clearer rules on pseudonymisation, a viable legal basis for AI training and operation under legitimate interests, and simplified rules for automated decision-making. Further positive steps include extended and risk-focused breach notification deadlines, limits on abusive data subject requests, harmonised rules on Data Protection Impact Assessments, and modernised cookie provisions. 

With the Financial Data Access Regulation (FiDA), the European Union aims to establish a modern data economy in the financial sector. With customers’ consent, financial institutions and third parties are to be granted access to customer data and the information generated from it. German insurers view the proposed framework with great concern, as the expected financial and personnel costs of the project would exceed any perceived benefits for companies and consumers by far. There is no evidence indicating whether customer-side demand exists, or to what extent it does. At the same time, the implementation of FiDA requires enormous effort and investment on the part of companies, which would be lacking for other important digital transformation projects (e.g. introducing AI applications and implementing DORA requirements). Given the current geopolitical context, it is also concerning that gatekeepers could gain access to the data of European companies and consumers, which would further strengthen the dominance of non-EU players and jeopardise Europe's digital sovereignty. Despite current discussions on a complete exclusion of gatekeepers as data users, a legally certain and politically feasible exclusion does not seem possible at this stage.

The global minimum tax must be implemented in Germany in a way that is as easy to administer as possible. Simplifications of the rules as they have recently been published by the OECD as part of the so called „Simplified ETR Safe Harbour“ are a step forward. However, there is room for further improvements, most importantly where the usability of accounting data (reporting packages) and the treatment of investment entities are concerned. The fact that some major economies such as the US, China and India have not implemented the OECD´s minimum tax rules, raises level plaing field concerns. Therefore, any negative trends emerging in respect of the level playing field for MNE groups and resulting competitive imbalances have to monitored and rules adjusted as necessary.

Moreover, the decluttering initiative by the EU may serve as an important contribution to more legal certainty and less red tape, in particular reporting obligation on cross-border arrangements which have no relevant effect on the protection of Member States´ tax bases. Overlapping rules rules with similar policy objectives should be streamlined. For example, in light of the minimum tax the controlled foreign company (CFC) rules in ATAD may be cut back as both regimes aim at securing a level of minimum taxation and the avoidance of profit shifting.

The Association participated in the consultation on the EU proposal for a directive on the harmonisation of insolvency law and welcomed the proposals contained therein to strengthen creditors' rights. However, the planned pre-pack procedure and the introduction of simplified liquidation procedures without an administrator for micro-enterprises are viewed critically due to insufficient creditor participation and risks of abuse.

Liability insurance is a pillar of the European legal and economic system. It ensures that individuals and businesses are held accountable for damages they cause, while providing victims with swift and fair compensation. As Europe faces technological, environmental, and social change, liability insurance supports innovation, consumer protection, and the rule of law.

PFAS, often called “forever chemicals,” are resistant to water, dirt, grease, oil, and extreme temperatures, but many of these substances are considered harmful to health, making their use highly controversial. To prepare for risk dialogues between industry and policymakers, GDV is developing a non-binding guideline to help clarify the scientific and legal assessment of PFAS-related risks. This approach benefits both sides: manufacturers and users gain a clearer understanding of the potential dangers, while engagement with insurers encourages them to analyse their own risks more closely and explore ways to mitigate them.

Private third-party litigation funding (TPLF) refers to the practice of outside investors financing legal claims in exchange for a share of any compensation awarded. TPLF in the EU poses risks to innovation, investment and the competitiveness of European businesses by potentially encouraging speculative litigation. A growing market for litigation funders operating without transparency or registration could undermine the integrity of civil justice systems and increase costs for defendants and companies. GDV therefore calls for EU-level regulation of private litigation funding, including measures such as registration of funders, transparency requirements and limits on funder remuneration. 

In light of structural changes in the financial system and heightened risks to financial stability due to the new geopolitical landscape, measures to further strengthen the macroprudential framework for the so-called non-bank financial intermediation (NBFI) sector are being considered at the EU and global level. GDV agrees that a comprehensive and effective macro-prudential framework is warranted, encompassing all NBFI activities. However, regarding macroprudential reforms, a risk-oriented approach that fully recognizes the heterogeneity of the NBFI sector and the already existing regulatory framework is crucial.

The insurance sector plays a unique role in the economy and the financial system, and its risk profile is distinct. Due to the essential functions the insurance sector performs, it is already highly regulated and supervised, including macroprudential oversight. With the Solvency II review, further macroprudential tools and measures were introduced. Therefore, the insurance sector should always be treated separately and not be included in discussions on the “NBFI sector” and its regulation. Instead, any concerns regarding potential gaps in the regulatory framework should be addressed within the context of insurance supervision.

Our role is to assess and compensate for economic damage to motor vehicles caused by road accidents, storms, and malfunctions. Despite the rising costs of spare parts and repairs, we remain committed to fulfilling our mission of compensating for vehicle damage. This allows drivers to maintain their mobility, even as cars become increasingly electric and connected. We are also committed to improving road safety by addressing all aspects of vehicle safety, traffic infrastructure, and traffic behaviour. To this end, GDV invest 1 million euros per year in research into road accidents and prevention.

With a wider range of models and an increasing population, electric cars are becoming more widespread: a trend that is also reflected in the damage statistics for electric vehicles. However, the average comprehensive insurance claims are still 15 to 20 percent higher than those for comparable combustion engine. One important reason for this is that electric cars spend significantly longer in repair shops than combustion engine vehicles, resulting in higher repair costs. In addition to the uncertainty surrounding fire risk and the subsequent repair delays, traction batteries in electric cars are sometimes inadequately protected by their design, making replacing or repairing defective batteries difficult.

Significantly higher long-term repair costs could hinder the acceptance of electric cars. This is why GDV is in favour of improving the options for repairing and replacing batteries at a modular level, as well as increasing the availability of spare parts.

Since 2021, all newly registered electric vehicles in the EU have to be equipped with an Acoustic Vehicle Alerting System (AVAS). This emits an artificial sound to be acoustically similar to an internal combustion engine of the same vehicles category and to indicate the form of vehicle behaviour.  However, research commissioned by the GDV Accident Research showed that the acceleration of electric vehicles with AVAS is still perceived worse than that of an internal combustion engine. Therefore, we urge the Commission to engage on UN ECE Regulation 51.138 in a constructive manner.

Motor Third-Party Liability (MTPL) insurance remains the cornerstone of victim protection in road traffic accidents. As vehicles evolve, the insurance system already in place remains fit for purpose in the automated era. Insurers guarantee swift and unconditional compensation to victims and ensure product accountability by pursuing recourse against manufacturers when a technical defect causes harm. Therefore, EU rules must safeguard existing levels of compensation and allow insurance systems to adapt, not be replaced, as automation progresses.

Timely, granular, and standardized access to vehicle-generated data (e.g. event data, ADAS activation, system status) is essential for insurers to assess risks, manage claims, and price coverage fairly. Without such access, claims resolution is delayed, and liability clarity is compromised, particularly in crashes involving automation. Car manufacturers control vehicle data, giving them an unfair advantage in telematics-based insurance, without being subject to the same regulatory oversight. Therefore, equal, secure, real-time access to in-vehicle data, functions and resources must be guaranteed under EU law to preserve a competitive and consumer-friendly market.
 

The German Insurers Accident Research (Unfallforschung der Versicherer – UDV), part of the German Insurance Association (GDV), aims to improve road safety by covering all aspects of vehicle safety, traffic infrastructure and traffic behaviour. To achieve this goal, the UDV commissions research on road accidents and prevention with a budget of 1 million euros per year. Relevant projects are, for example, studies concerning the fitness to drive of senior car drivers, the new demands of automated driving, or the inclusiveness of electric vehicles towards vulnerable pedestrians. The results are published on our website www.udv.de.

The Occupational Pensions Strengthening Act (Betriebsrentenstärkungsgesetz) provided new momentum for occupational pension system in Germany. The current coalition treaty presents ideas on strengthening social partner models (SPM) and considerations for higher returns for classic occupational pension provisions. As with private pensions, flexibility of guarantees is key to increase returns and by that the attractiveness of workplace pensions and enhancing coverage.   

The first SPMs based on collective bargaining agreements have been launched. To further unfold their potential, it should be assessed where more legal certainty is needed for the social partners to set up such agreements. For instance, the responsibilities for the social partners concerning capital investment are being discussed. Another issue is the possible participation of employers and employees that are not subject to collective bargaining agreements.

The focus on small and medium sized enterprises as well as on people with low incomes remains key. Models for automatic enrolment on a voluntary basis and on company level can set new incentives. Besides, the targeted support for low-income earners needs to be dynamized in line with the general income development.

The coalition agreement envisions a fundamental reform of private old-age provisions. Meanwhile, a focus group at the Federal Ministry of Finance has presented its recommendations for the future design of subsidised private pension. For insurers, the final report contains both reasonable points as well as critical aspects.

On the positive side, the state fund discussed in the coalition agreement was rejected by a clear majority: Private old-age provision should be organised by the private sector and remain voluntary. There was also broad agreement that subsidies should be increased and made more dynamic. An easy to understand, more attractive, and transparent subsidy system that automatically adjusts to income development is overdue some 20 years after the last major reform. In future, the self-employed should as well be included in the governmental support of private old-age provisions. Besides, low-income earners remain an important target group, here. They should also be better supported in occupational pension systems.

However, the ability to plan and security in old-age provision will be weakened if products without any guarantee and lifelong benefits are allowed in subsidised private old-age provision. Guarantees and annuitisation shall remain possible according to the majority of the focus group but would no longer be a core component. Certainly, the nowadays required 100 percent premium guarantee must become more flexible. A reduced guarantee requirement of, for instance, 80 percent would already allow for more opportunity-oriented investment. At the same time, stability and predictability would be guaranteed. Future legislative measures must consider the fact that lifelong expenditures require lifelong incomes, also to prevent people from falling into old-age poverty.

The federal government in Germany is planning to make old-age provision compulsory for newly self-employed people. Those who do not want to pay contributions into the statutory pension system can opt out with a private pension product. This requires the product to be insolvency and seizure-proof and to offer protection above the social welfare level.

These requirements are already met by the basic pension (Basisrente), which was originally developed for the self-employed. It is equal to the statutory pension in terms of taxation. Also, it is safeguarded when drawing unemployment benefits and provides lifelong retirement income. Any opting out should be straightforward and simple. A one-size-fits-all insurance, however, would undermine the reasonable intention of providing better coverage for the self-employed.

Property insurance protects homes, businesses, and infrastructure from damage and loss. It is essential for financial stability, urban development, and disaster recovery. As the EU promotes sustainable construction and energy efficiency, insurers help manage emerging risks and support resilient housing.

Houses are safe spaces, and GDV members help ensure they stay that way by supporting sustainable, resilient and well-protected living environments across Europe. Sustainable housing construction brings new challenges for insurers, particularly as novel building materials and hybrid construction methods shift risk profiles and demand detailed risk-analysis throughout the building lifecycle. GDV welcomes the New European Bauhaus initiative and endorses its focus on creating sustainable and resilient neighbourhoods, recognising that such initiatives align with insurers’ interests in reducing exposure to climate- and construction-related risks while promoting smarter, future-proof living spaces.

In principle, lithium-ion batteries can be assumed to be safe to use when handled properly. Improper handling or technical defects can lead to thermal runaway. This uncontrolled overheating usually results in a fire, possibly accompanied by an explosion, but always accompanied by the release of toxic smoke. GDV supports regulators on Federal and European level to strengthen the safety of batteries in people’s daily lives. Together with VdS Schadenverhütung, GDV works on guidelines for prevention, but it is crucial that policymakers address the pressing issue of single-use batteries to lower risk of battery fires, e.g. in recycling facilities.

Solvency II is the core prudential and supervisory framework for insurers and reinsurers in the EU. The framework was originally introduced in 2016 and has recently been reviewed in order to boost insurers' ability to invest and support the transformation of the European economy. Throughout the review, GDV highlighted that any changes to the system, in particular regarding capital requirements, must be justified by evidence- and risk-based findings. Due to the very long-term contracts prevalent in the German life insurance market, the treatment of such business under Solvency II is a particular focus for GDV. In addition, reducing operational and administrative burdens as well as providing effective proportionality measures for smaller (re)insurers are priorities for us.

While the central aspects of the Solvency II review were concluded with the adoption of the revised Directive and Delegated Regulation, EIOPA continues to develop further technical standards and guidelines for application. The changes to the Directive will also have to be transposed by Member States into national law by January 2027.

Further information: 

• Solvency II reform nearing completion: EU establishes reliable framework for insurers

The International Association of Insurance Supervisors (IAIS), of which both EIOPA and BaFin are members, adopted the Insurance Capital Standard (ICS) in late 2024. The standard has been under development since 2014 and is intended to provide a globally comparable risk-based benchmark for the capital adequacy of internationally active insurance groups (IAIGs). The main objectives are to protect policyholders and to contribute to financial stability. The ICS therefore aims to provide increased mutual understanding and greater confidence in the cross-border analysis of IAIGs among supervisors. German insurers welcome the endeavour for an internationally comparable capital standard and contributed comprehensively to the development process. With Solvency II, the regulatory and supervisory framework for European (re)insurers already meets – and in many cases exceeds – the requirements of the ICS.

From January 2027, the new Insurance Recovery and Resolution Directive (IRRD) will require many insurance undertakings across business lines to allocate considerable resources on a regular basis to the drafting of recovery plans and the submission of exhaustive data and information to national resolution authorities for preparing resolution plans – regardless of whether these undertakings are prone to fail or likely to fail. The IRRD’s provisions on financing arrangements will also lead to significant additional costs for the industry, despite the Commission’s efforts to strengthen the competitiveness of EU businesses. Moreover, it remains unclear how the IRRD will interact with the broad powers of national supervisors towards insurance and reinsurance undertakings in difficulty or in an irregular situation provided under the Solvency II Directive.

This is why GDV calls for a stop-the-clock Directive on the IRRD to allow more time for implementing a proportionate, risk-based and lean recovery and resolution framework. German insurers remain committed to contributing to the development such a framework. However, this should be done with a sense of proportion, reflect the longer time horizon for resolution in insurance compared to the banking sector, and avoid unnecessarily jeopardizing the functioning of the proven German protection schemes. Furthermore, due consideration should be given to the option of targeted amendments to the Solvency II Directive instead of implementing a separate framework.

For a sustainable and climate-neutral commitment, undertakings need comprehensive, reliable and easily manageable information about the risks and impacts of their business practices. With the so-called “taxonomy”, a unique classification system is being created in the European Union for this purpose, defining what sustainable management is. Insurers looking to invest in undertakings in the real economy need this information so they can gauge how sustainably they are investing or whether they can take on certain risks. In the future, undertakings are to make this sustainability information available in a standardised and comparable form on the basis of the Corporate Sustainability Reporting Directive. Through a "European Data Access Point", the information will be digitally accessible and automated. In this way, the basis for sustainable investment decisions is constantly being improved. Insurers are both users of sustainability information and providers of data (as investment objects). From this dual perspective, they have put forward proposals to ensure that sustainability-related reporting requirements are not overloaded. The principle of proportionality must be upheld and the reporting effort must be contrasted with concrete added value.

Here you can find further information:

• Sustainability positioning
• CSRD Position paper
• ESRS Position paper

German insurers strive for climate-neutral business processes in Scope 1 and 2 of the GHG Protocol by 2025. This includes electricity and heat emissions from their own office facilities and data centres as well as fuel emissions from the company's own vehicle park. In addition, there should also be noticeable reductions in downstream emissions from Scope 3 by 2030 at the latest. Every year, GDV reports on the emissions of its members, in future also from activities such as business travel by air and rail, home office, commuting of staff to work or outsourcing and cloud.

For a significant reduction in CO2 emissions, insurers - like the other economic sectors - need the decarbonisation of the energy sector and heat generation, a mobility transition and accelerated digitalisation. In addition to the voluntary efforts of companies, energy efficiency will become mandatory in Germany in the future with the implementation of the EU Energy Efficiency Directive. In the GDV's view, the legal framework should take into account factors such as investment security, feasibility and proportionality in addition to pure energy-saving targets.

Further information in our Sustainability positioning

The extension of renewable energies, innovative technologies and changed production principles are essential to reduce greenhouse gas emissions and resource consumption. The German government has set itself ambitious goals in this area: An ambitious circular economy strategy, the establishment of a hydrogen market and ambitious expansion targets for electricity and heat from renewable sources. Insurers support these developments by designing insurance coverage for innovative processes and risk technologies. We want to contribute our many years of experience in loss prevention so that resources are not depleted by avoidable losses: Innovation and change must proceed swiftly and safely at the same time. This also creates public acceptance. 

The circular economy, for example, needs sufficient operating space to be able to store, sort and process materials until they are fed back into manufacturing processes. This strengthens the protection of people and property. High safety standards should continue to apply to the installation and operation of photovoltaic plants, biogas and energy storage systems, especially with regard to fire and environmental protection.  We also welcome the Federal Government's initiative to establish the features "service life" and "repairability" as product characteristics through the principle of "sustainability by design". This supports our work on solutions to anchor guiding principles of sustainable action such as "repair instead of buying new" or "build back better" in insurance products.

Further information in our Sustainability positioning.

Greenwashing poses a threat to the stability and trustworthiness of the financial market. These are values which are also of outstanding importance for insurers as financial market participants. Insurers therefore support the efforts at European level to establish credible and practicable regulations to avoid greenwashing.

The regulations must, however, remain practicable. If financial market participants apply the current regulations in a credible manner according to recognised principles, this must not be interpreted as greenwashing. Otherwise, there is a danger that any statements on sustainability, including legitimate ones, will be avoided in order not to expose oneself to the danger of greenwashing.

You can find further information in our statement.

Sustainability is of great and constantly growing importance in insurers' investments. Sustainability criteria are already applied to around 90 % of investments. Insurers financed around 1,600 wind and solar energy projects in 2021. In its sustainability positioning, the sector has also set the goal of making its own investments of €1.9 trillion completely climate-neutral by 2050. On the way there, the insurers were the first financial sector in Europe to publish a carbon footprint for large parts of their investments at the end of 2022 (71 tonnes CO2 equivalent / million euros).

For further information, see this position paper. 

The taxonomy established by the Delegated Regulation on technical screening criteria (TSCs) is one of the core EU regulations in the field of sustainable finance, and has GDV's express support. This taxonomy determines when an economic activity contributes to an environmental objective and can therefore be considered environmentally sustainable. It creates a single language for green activities.

But work on the taxonomy is only just beginning. A large number of activities are (still) not included in the taxonomy, and many asset classes in which insurers invest, such as e.g. government bonds, are (still) excluded. If the taxonomy is to be applied in practice in a meaningful way, the inclusion of additional economic activities and asset classes is essential. The taxonomy will also have to be internationalized so as to make it usable for investors with worldwide investments, such as insurance companies. Accordingly, an extension of the taxonomy is urgently necessary.
But new taxonomies, such as e.g. a social taxonomy, should not be introduced right away, and should instead be given the chance to benefit from our experience with the green taxonomy.

Further information: 

• Call for Feedback
• Statement 

Transport insurance is one of the oldest branches of the insurance industry. The transportation of goods has always been dangerous and will continue to be so in the future. Technological advances in recent decades have magnified the scale of individual risks in logistics. A single large container ship and its cargo can be worth up to 900 million euros. This is why transport safety and cargo securing at sea are key focuses for transport insurers and the German Insurance Association (GDV).

Numerous containers are lost at sea every year, sometimes with significant consequences for the environment, shipping, and insurance coverage. Inconsistent practices among classification societies, especially divergent methods for assessing stability, acceleration forces, and load stresses, create safety gaps and elevate the risk of container loss under adverse sea conditions. Moreover, many container ships operate at near-maximum capacity, pushing cargo securing systems beyond their design margins. Until binding international regulations for container ships are in place, GDV recommends that CSS Code Annex 13 also be applied to this class of vessel on a transitional basis. 

Meanwhile, the risk of fire is a major concern for insurers in the maritime transport sector, particularly as containers and vessels are carrying increasing amounts of combustible goods and electric vehicles with lithium-ion batteries. According to GDV statistics, approximately 62% of major maritime losses (above USD 20 million) were caused by fires over the past decade. GDV has issued a warning that many ships still use outdated firefighting and detection systems and is calling for the adoption of automated fire detection systems and high-pressure water mist suppression systems. It is also calling for fire zones to be segmented and for stricter standards to be adopted for the transport of batteries. These requirements should be codified through the International Maritime Organization (IMO) and other global regulatory bodies to ensure a level playing field for shipowners worldwide.

Drivers and cargo require security during rest periods. However, truck parking areas are repeatedly becoming crime scenes, with one in three cargo thefts occurring while the truck is parked. Well-organised criminals steal millions of euros' worth of goods and sometimes use ruthless violence against drivers. GDV, together with the employers' liability insurance association for vehicle operations and the German Federal Criminal Police Office, therefore, supports the EU standard for safety and service standards for safe and secure truck parking areas.