SFDR: German Insurers Call for a Simple and Practical Reform
German insurers support the reform of the Sustainable Finance Disclosure Regulation (SFDR) initiated by the European Commission and advocate for a clear, comprehensible, and practical implementation. The goal must be to turn the SFDR into a functional information tool for investors – especially in the retail segment.
Current product information is often too technical, too extensive, and inaccessible for many consumers. To make sustainable investments understandable and comparable for customers, there needs to be clear, concise core statements about sustainability features. Additional information should be made available digitally rather than in lengthy paper formats.
At the same time, it is crucial to closely align the SFDR with existing regulations such as MiFID II and IDD. Only when advice and disclosure are coordinated can sustainable investment be implemented in a customer-friendly and efficient way in practice – without contradictory requirements or additional bureaucracy.
From the perspective of the insurance industry, it is particularly important that the SFDR takes into account the specific nature of insurance-based investment products. These combine capital market investments with insurance coverage and collective reserves in the guaranteed assets. Life insurers, in particular, invest in a long-term, security-oriented, and broadly diversified manner – a future categorization system must appropriately capture these product types.
The proposals of the EU Platform on Sustainable Finance and the German Sustainable Finance Advisory Council provide important reference points in this regard. The further development of the SFDR should be guided by these suggestions – while avoiding duplicate regulation with other frameworks such as the CSRD.
The full response to the EU Commission’s consultation can be found here:
