Date: 15th January 2021

BETTER FINANCE fully supports EIOPA's fundamental approach to preventing "green-washing" and "green bubbles". ESG investments must be submitted to the same risk assessment procedures (ORSA) as any other investment by insurers.

BETTER FINANCE also supports EIOPA’s proposal fora new short section in the SFCR with information specifically aimed at policyholders. It should be mandatory for this new section (a two-page document) to be sent to policyholders together with the annual pension benefit statements. For consumer organisations like BETTER FINANCE or BdV the SFCRs constitute essential basic information tools for the additional analysis of capital and solvency requirements.

We continue to support EIOPA’s objective to develop principles for a minimum degree of harmonisation in the field of Insurance Guarantee Schemes (IGS).