The ESAP will allow European insurers — which are Europe’s largest institutional investors — to access robust, comparable and reliable financial and ESG data in an electronic machine-readable format. This will help insurers to steer their investment portfolios even more effectively towards sustainability objectives, and to comply with disclosure requirements.
The insurance sector would, however, like to stress the following points:
• The EC should develop an implementation roadmap specifying a phased approach that gives priority to ESG data required under the Corporate Sustainability Reporting Directive, the Sustainable Finance Disclosure Regulation and the EU Taxonomy Regulation. Financial, prudential and other types of information can be incorporated in later phases.
• Access for users, such as insurers, who require the ESAP data to make sustainable investment decisions and to comply with regulatory reporting requirements, should be free. A small fee to access and use ESAP data would be acceptable, if it is deemed necessary to ensure the rapid development of a well-functioning, reliable and user-friendly platform. However, such a fee should be significantly lower than for data providers who will use the data as part of their business model.
• The inclusion of information from packaged retail and insurance-based investment products (PRIIPs) and pan-European Pensions Products is premature. An assessment should be made, when the review of the PRIIPs framework is finalised, to determine whether the revised PRIIPs key information document is fit for purpose and whether the information should be included in the ESAP.
• Strong governance and expert input will be important for the development of the ESAP to be a success. Insurers support the establishment of an advisory steering board, composed of users, preparers, national and European competent authorities to advise the European Securities and Markets Authority on the set up and running of the ESAP.
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