Positions

Not every algorithm constitutes artificial intelligence (AI). The definition of AI is critical to the scope of future regulation. To be future-proof, the definition should include only AI-specific concepts and not well-known mathematical methods, for example, linear models or statistical methods. Algorithms that do not incorporate some form of machine learning or self-optimisation should not be subject to AI regulation.

The use of artificial intelligence (AI) requires the trust of all parties involved. AI systems for premium calculation, underwriting and claims settlement in the insurance sector are subject to strict requirements by general laws as well as the stringent regulatory framework for financial services. They also meet customers' demands for trustworthy handling of their data. Data and IT security and data protection are a matter of course for insurers' data-based business models. 

Existing legal regulations on data protection, consumer protection, protection against unfair business practices and protection against discrimination also apply in the field of AI because they are technology-neutral. Supplemental regulation should be considered only for high-risk AI applications. A correct delineation between non-risky and high-risk AI applications is crucial. The classification of sectors as high-risk should be made according to comprehensible criteria and not in a blanket fashion. The insurance sector is not a high-risk sector due to existing technology-neutral regulation. For this reason, the commitment of the traffic light coalition to "focus on a multi-level risk-based approach and avoid ex ante regulation that inhibits innovation" in the negotiations on the EU's Artificial Intelligence Act is also correct.

For further information see our position paper.

German insurers welcome the plan to create a binding framework for a precautionary federal climate adaptation strategy and cooperation between the federal government, the states and other administrative bodies in all necessary fields of action. This draft law is a first important step towards countering the threat of the "climate crisis" in a structured manner at the state level as well. Nevertheless, on closer examination, the draft bill raises numerous questions. Among other things, it is questionable whether the intended goals for containing the climate crisis can actually be achieved with the methods and measures described. In particular, we see a need for action in climate risk analysis and monitoring.

The global minimum tax and other reform initiatives at the OECD and EU level must be implemented in Germany in a way that is as easy to administer as possible. They should also be taken as an opportunity to put existing anti-abuse regulations to the test. Since not all details of the global minimum taxation have yet been determined, a time delay should be granted for the sanctioned application of the complex rules after the actual start date (1 January 2024). In this context, it would also be consistent to lower the 25 percent threshold below which foreign companies are assumed to be low-taxed under the Foreign Tax Act to the globally agreed minimum tax level of 15 percent.

Further information can be found in our statement.

Fortunately, the traffic light coalition has agreed to expand safe parking areas for trucks on and around highways. In perspective, this could reduce the high number of cargo thefts. According to the calculations of several trade associations with the participation of GDV, there are around 26,000 cargo thefts from trucks in Germany every year. Their financial damage is considerable: The stolen goods alone are worth EUR 1.3 billion, and further damage of EUR 900 million is caused by contractual penalties for delivery delays, repair costs, and lost sales and production by the actual buyers. In comparison, the number of secure parking spaces is immeasurably small. This suits the perpetrators - mostly highly professional international gangs - as does the low pressure from searches. Such pressure should be brought to bear in tandem with the expansion of secure truck areas, following the example of the successful cross-border "Cargo Project” of the Saxony-Anhalt State Criminal Investigation Office.

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 Digital Operational Resilience Act (DORA) has been in force since January 16, 2023 and has an implementation period of 2 years. It directly applicable and does not need to be transposed into national law.

The aim of the regulation is to improve the digital operational resilience of EU financial entities. Regulated entities must take the necessary security measures to mitigate cyber-attacks and other risks. To this end, DORA sets uniform requirements for ICT risk management, incident reporting, systems testing and auditing, and third-party risk management.

It is particularly important to integrate DORA as smoothly as possible into existing regulatory requirements, especially in interaction with the German supervisory requirements for IT in insurance undertakings (VAIT). Duplicate reporting obligations and excessive testing requirements must be avoided.

The Data Act is a legislative proposal from the European Commission for harmonised rules on fair access to and use of data. The law gives users of Internet of Things (IoT) devices the right to request and share data generated by their use with third parties. The insurance industry views the Data Act as generally positive. It strengthens data sovereignty and fair competition. Companies will be better protected against abusive contractual clauses. It will also be easier to switch cloud providers in the future, as the GDPR obliges providers to achieve greater interoperability.

However, the Data Act creates legal uncertainties regarding the further processing of personal data from IoT devices. The reason for this is that it is not sufficiently differentiated from the General Data Protection Regulation (GDPR). In some cases, the Data Act is even expected to tighten up the GDPR. The EU Commission's legislative proposal also provides for very far-reaching obligations to disclose data of all kinds to public authorities, which unfortunately are only marginally limited in the trilogue agreement of the EP and the Council. The provision of data by companies to public authorities should be strictly limited to emergency situations.

Digitalised data create value and prosperity. Insurers handle a lot of data along their value chain because they have to assess risks correctly, develop appropriate offers and provide help quickly in the event of a claim.

The promotion of data infrastructures, as agreed by the German government, is the appropriate policy in this regard. It is also sensible to improve access to data from public authorities and registers (open data). The emphasis should be on trust and security in line with efficiency and user-friendliness. Otherwise, data-based business models of European companies will not be able to compete with American tech providers and Chinese state-owned enterprises.

For further information see our article.

On 28 June 2023, the EU Commission presented its proposal for a regulation on a framework for financial data access.

The framework requires financial institutions to provide their customers with online permission dashboards. With the assistance of the dashboard, customers will be able to access their own data without undue delay, free of charge, continuously and in real time. In addition to that, customers will be able to share their data with third parties via the dashboard.

In order for the framework to be a success, GDV believes that the following conditions must be met. First of all, the framework should follow a stepwise evidence-based implementation that prioritises proven use cases with tangible customer benefits. Once the framework is established, it is crucial to maintain a true level playing field across all participants. When data is shared, there should be a fair compensation for it. Companies should not be obliged to share trade secrets. The data sharing should not be a one way route from data holders to data users, but should work the other way round, too. Lastly, other data spaces outside the financial sector should be developed swiftly and be accessible by insurers (Connected Vehicles, Internet of Things, Health Data Space, etc.).

You can find further information in our article.

Innovation-friendly data protection legislation is a prerequisite for the development of AI applications. High standards of personal data protection and consumer sovereignty over their data must be balanced with practical options. Experience with the General Data Protection Regulation (GDPR) so far shows that this balance has not yet been achieved in all areas. To ensure that the GDPR can continue to play its role as an international standard-setter in the future, the next evaluation should be used as an opportunity to remove existing obstacles. It must be possible to use data to train AI in a legally secure manner. Fully automated decisions that enable the rapid conclusion of contracts and the rapid settlement of claims in the interests of customers must not fail because of data protection hurdles. The German government's goal of reaching an ambitious agreement with the US on legally secure data transfer, in line with GDPR rules, should be given high priority.

Further Information:

• Position on the evaluation of the General Data Protection Regulation (GDPR)

Fires in electric bus depots have demonstrated the limitations of traditional fire safety concepts. Not all otherwise typical fire safety measures can be effectively and sensibly implemented in this case, and alternative forms of propulsion involve new risks for bus depots.

In order to provide practical assistance in this regard, insurers worked with transit companies to create a guide on "Fire Safety in City Bus Depots" (VdS 0825). The loss prevention measures described in this guide can also be used to improve fire safety in regional and tour bus depots. In the guide, the German Insurance Association (GDV) explains which fire safety risks should be focused on, as well as other aspects which merit consideration. The guide also discusses how, in an environment where a fire has already broken out, rescue personnel and/or firefighting equipment can be used to minimize risk and/or damages. Any loss prevention measures which can be taken by public transportation operators can also have a decisive impact.

The number of electric vehicles is increasing. They are quieter than vehicles with internal combustion engines and may be harder for other road users to perceive. 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, the AVAS regulation should be further developed to include acceleration.

The Insurance Capital Standard (ICS) 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 of the ICS are to protect policyholders and to contribute to financial stability. The ICS aims at comparability of outcomes across jurisdictions and is therefore meant to provide increased mutual understanding and greater confidence in cross-border analysis of IAIGs among group-wide and host supervisors. The German Insurers welcome the endeavour for an internationally comparable capital standard and contribute comprehensively to the development process. A transparent process and a risk-based approach that ensures the protection of policyholders and enables globally uniform market conditions are particularly important for insurers.

The trilogue negotiations on the review of Solvency II are ongoing. The prudential framework was originally introduced in 2016 and is now being examined for potential adjustments in the context of the review. It is of great importance that any changes to the system, in particular regarding capital requirements, are justified by evidence- and risk-based findings. For example, unjustified changes to the interest rate extrapolation significantly limit insurers' ability to make long-term investments and thus hinder progress in the transformation of the European economy. In the area of capital requirements, many aspects of the European Parliament's Report are more in line with the review's original objective of creating more capacity for investments in the future. The GDV criticises that the new framework for smaller insurers is not very practical, especially for the German market. The criteria for identifying such insurers appear too restrictive and it is expected that only a few German insurers will be able to benefit from the proposed alleviations. However, the association supports the idea of relieving companies with a low risk profile regarding their sustainability reporting obligations. At the same time, no double reporting requirements should be introduced if these are already anchored in other European regulatory frameworks.

Further information: 

• Media release
• Consultation paper

With regard to the proposed changes to the rules for "hit and run" offenses, insurers strongly oppose any restrictions on their ability to secure evidence. We must be able to ascertain the cause and origin of the accident beyond any doubt, and this also applies e.g. to the question of whether drugs or alcohol were involved. Whether or not the person who caused the accident was in a condition to drive can only be determined immediately after the accident.

We must also ensure that road accident victims are protected. If a driver unlawfully leaves the scene of an accident, the victims must not be left to deal with their property damage alone. If the person responsible for the accident cannot be determined, the victims would either have to pay for the repairs themselves or utilize their motor vehicle comprehensive cover, in which case they will be downgraded in their full comprehensive coverage policy and their safe driver bonus will be diminished. They may also be required to pay a deductible.

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.

Credit insurers recognise the EU Commission's aim of improving payment behaviour in business transactions and thus protecting SMEs in particular from late payments. However, credit insurers consider the measures proposed by the EU Commission to this end, in particular the conversion of the current Late Payment Directive into a regulation, the introduction of a short absolute maximum period of 30 days for payments in commercial transactions and the introduction of high automatic interest on late payments, to be counterproductive and impractical. The proposed measures interfere disproportionately with the contractual freedom of business partners, disregard country- and sector-specific characteristics and prevent flexible reactions in times of crisis. They will cause liquidity problems for fragile companies and increase their risk of insolvency.

Further information can be found in our statement.

GDV has participated in a consultation on the revision of the EU Package Travel Directive, which includes a review of the rules on insolvency protection. GDV considers the current regulations to be largely suitable and does not believe that a renewed expansion of consumer protection in this area is appropriate.  

You can find further information in our consultation paper.

Driver assistance systems (L1, ADAS) are effective and must quickly find their way into the vehicle fleet in order to be effective. Legislation and consumer protection (EuroNCAP) help here.

Assisted (L2) and automated (L3) driving functions that maintain lane and distance, on the other hand, are primarily comfort functions. Their contribution to greater road safety is still uncertain. The design of the human-machine interface is the critical factor here. Although the driving functions are intended to reduce the stress on the driver, they can lead to new stresses because the driving task changes fundamentally. Therefore, the development and distribution of these systems should be closely accompanied by independent tests and investigations. L2 systems, where the driver no longer needs to have his hands on the steering wheel (hands-off), lead to a further intensification of this problem. The UDV demands strict rules for these systems (eye position control, function only on motorways) to ensure that road safety remains guaranteed.

The proposed tightening of the Autonomous Driving Act which was announced in the coalition agreement must not jeopardize two fundamental aspects of the Act, which was enacted in 2021. 

Firstly, with regard to liability for accident victims, the clear and simple rule in the current law must be retained: if someone is injured due to the operation of a motor vehicle, or if property damages occur, the owner's motor liability insurance must cover the damages. No one should have to worry about being treated worse than before after an accident involving a self-driving car.  

Secondly, the Autonomous Driving Act allows victims to obtain access to the vehicle's operating data in case of an accident. Especially when a self-driving car is involved, we must be able to determine who made the mistake and who is ultimately responsible for the accident. Those who bring defective systems to market must answer for their actions within the framework of applicable law. Access to this data would allow motor insurers to investigate and enforce product liability claims.

Modern cars produce and require large amounts of data. This data is a valuable asset: it holds great potential for new car-related services. How well the market will function in the future depends primarily on the question of who can access the car data, when and how, and communicate with the drivers. Here, the automotive industry is currently establishing a system according to which owners or drivers can only forward their data to a third service provider via the manufacturer's servers to a limited extent. This would allow manufacturers to control data flows and restrict competition. From the insurers' point of view, however, the data does not belong to the manufacturers, but in the hands of the consumers. They must be free to decide to whom they transmit their vehicle data. On the other hand, such a transmission must be technically possible for all providers - manufacturers, workshops, automobile clubs, insurers - without any problems.

Together with other industry associations, such as the German Association of the Automotive Industry (VDA), the Association of International Motor Vehicle Manufacturers (VDIK) and the German Federation for Motor Trades and Repairs (ZDK), the German Insurance Association has long welcomed and actively supported the initiative by Germany's Federal Ministry of Transport and Digital Infrastructure to expedite the digitization of motor vehicle registrations and to offer internet-based online registrations through the option of a key account interface, a legal entity which files registration applications for itself or for third parties (Phase 4 of the "i-Kfz" project). 

The legal basis for internet-based online registrations via the key account interface will be found in an amended Motor Vehicle Registration Ordinance. GDV, in conjunction with the other industry associations, has therefore submitted its comments on the bill to amend the Ordinance on the Registration of Motor Vehicles for Road Traffic and other statutes, dated 15 June 2022, and on the German government's bill for an Act Amending the Online Access Act, as well as other regulations of the Federal Ministry of the Interior, dated 17 January 2023.

It is also true for insurance companies that they unfortunately need a considerable amount of time and effort to shoulder the ever-increasing bureaucratic burdens. In this respect, we welcome the fact that the current federal government is continuing the approach of reducing an existing bureaucratic burden for each new one to be introduced (so-called one-in-one-out rule). It is also to be welcomed that the federal government is keeping its coalition agreement promise and has now started work on a (tax) bureaucracy relief law. To this end, the GDV took part in a survey at the beginning of the year (2023), which was conducted by a committee of state secretaries of the Federal Government under the auspices of the Federal Ministry of Justice. An initial assessment by the Federal Statistical Office of the nine proposals submitted by the GDV shows that our proposals are implementable and can provide noticeable relief. The proposals should therefore now be submitted to the legislators for a decision as soon as possible.

Digital and secure identification of natural and legal persons is the basis for digital processes in administration and business. At the same time, identification must be both secure and user- and business-friendly. The insurance industry has long advocated the establishment of a European, barrier-free and non-discriminatory ecosystem for digital identities. In doing so, it emphasizes the integration of different identification procedures with the same level of trust and equally high user-friendliness. In this respect, the association supports the European efforts within the framework of the eIDAS amendment to provide a standardized architecture & reference framework (ARF) for the European ID wallet.

Adequate insurance protection against natural hazards requires valid information for risk assessment. For this purpose, science, authorities and the insurance industry have developed natural hazard models. Examples are the flood and heavy rain hazard classes that are stored in ZÜRS Geo. The insurance industry is currently developing a flash flood model.

Homeowners can insure their property against further natural hazards, such as flooding and heavy rain, as part of their homeowners' insurance with an insurance against natural hazards. In the wake of the flood disaster in 2021, a discussion has flared up again about the introduction of compulsory insurance against natural hazards. The German insurers reject a singular compulsory insurance without binding regulations for climate impact adaptation and prevention and continue to advocate for an overall concept. In addition to an insurance solution, this also provides for precautionary and protective measures. Prevention and climate impact adaptation, insurance and precautions for extreme catastrophes stand side by side as an inseparable unit. Insurers fear that without prevention, a spiral of ever more damage and ever higher premiums will be set in motion, which can overburden consumers financially.

Further information in our article.

Against the backdrop of climate change and the increase in extreme weather events, we advocate the introduction of uniform federal requirements for building in hazardous areas. The Building Code (BauGB) is the most important piece of planning legislation in Germany. Its provisions have a great influence on the shape, structure and development of the settled area and the "habitability" of towns and villages. It defines the most important urban planning instruments available to the municipalities. With this norm, the legislator regulates, among other things, the development of transport, utility and green spaces. It also provides the guidelines for building in outdoor areas.

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.

Fitness to drive of senior drivers is often discussed emotionally especially after serious accidents. Very quickly the public discusses whether the fitness to drive should be regularly checked of all senior drivers from a certain age. However, scientific studies consistently show that age is not a meaningful indicator for fitness to drive. Therefore, so called mandatory age-based screening schemes for senior drivers have proven not to be effective in ensuring road safety. However,  while the majority of senior drivers is still fit to drive on average they do exhibit typical driving errors and accident characteristics, especially from the age of 75 onwards. Therefore, it is important to support senior drivers in maintaining their driving competence as long as possible. For example, the GDV Accident Research developed the so-called feedback intervention for senior drivers. This is a one-time observation drive in real traffic with a qualified observer. Following the observation drive, the senior drivers receive a qualified feedback about their driving competencies and how to maintain them. In two evaluation studies the effectiveness in reducing driving errors have been demonstrated. The European Commission currently revises the European Driving License Directive. The validity of driving licences are supposed to be reduced to 5 years (instead of 15 years) from the age of 70 in case of renewal in order to allow for appropriate measure. That could be a feedback intervention for senior drivers.

The coalition parties are promoting the retrofitting of truck turn-off assist systems. Their Europe-wide installation has been mandatory in all new vehicle types since 2022 and will become mandatory in all new vehicles from 2024. According to the Insurers Accident Research (UDV), these safety systems could save the lives of around 30-40 pedestrians or cyclists in Germany alone every year - if they were installed in every truck.

The German Insurers are therefore in favour of continuing the funding until the entire truck fleet is equipped with the life-saving assistant systems; alternatively, a corresponding retrofitting of older trucks could be prescribed by law.

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 

Traffic and transport safety is not limited to the road. For years, German insurers have been observing increasing financial and ecological risks in shipping, particularly as a result of ever-larger container ships. In the case of large container ships, the current safety systems are no longer adequate for either the maneuvering characteristics or the fire hazards. 

On the one hand, for the past two years there has been an increase in the number of containers lost overboard in heavy seas - mostly as a result of lateral “rolling” seas. With container stacked up to twelve layers high, the lashings are no longer sufficient. If the containers fall overboard into the sea and break apart, the valuable cargo becomes waste and a hazard for coasts, fish, birds and other animals. 

On the other hand, fire extinguishing systems on container ships have hardly evolved at all in the last 40 years. As a result, effective firefighting is usually only possible from off board. On the high seas, fires are an enormous risk for the crew, the cargo and the ship. 

GDV has developed solutions to both problems and is campaigning for their implementation at the national, European and international level. 

Further information in our media releases:

• Insurers want plastic pellets classified as dangerous goods
• How to make container shipping safer again