Advice to the Commission on the Review of (Re)insurance Disclosures Under the Taxonomy Disclosures Delegated Act (European Insurance and Occupational Pensions Authority)

Summary

• EIOPA's public consultation on simplifying insurance Taxonomy disclosures received responses from 19 stakeholders between July and August 2026.p.3
• Analysis of 2024 annual reports showed that Taxonomy-aligned non-life underwriting activities represented an average of approximately 3% of total premiums covered by the KPI.p.11
• Taxonomy-eligible but non-aligned underwriting activities accounted for around 17% of premiums, while Taxonomy-non-eligible business represented approximately 80%.p.11
• In investment portfolios, average Turnover alignment and CapEx alignment for the analyzed sample were both below approximately 5%.p.14
• Solvency II reporting for 2023 showed that 37% of entities writing NatCat insurance in Fire and Damage to Property included risk-prevention measures, while 52% reported their absence.p.15
• Provisional 2025 Solvency II data showed a decline in NatCat products with risk-prevention measures to 29%, while negative responses increased to 55%.p.15

Key insights

1. EIOPA advises standardizing the numerator calculation of the underwriting KPI to cover only the premium portion explicitly allocated to climate-related perils for contracts covering natural catastrophe risks.p.4
2. EIOPA proposes narrowing the underwriting KPI denominator to the eight eligible Lines of Business, or alternatively mandating the three most climate-relevant lines while keeping five optional.p.4
3. EIOPA recommends renaming the underwriting metric to 'Adaptation Underwriting KPI' to explicitly clarify its sole focus on climate change adaptation.p.4
4. EIOPA proposes replacing the weighted average combined KPI with a single 'reference KPI' chosen according to whether investment or underwriting generates the highest Gross Written Premiums.p.4
5. EIOPA advises against introducing a new Green Insured Activities KPI to measure insured counterparties' alignment, recommending instead to revisit the concept in five years.p.5
6. EIOPA recommends removing nuclear and fossil gas breakdowns from reporting templates as they are non-applicable for underwriting and immaterial for investments.p.5
7. The European Supervisory Authorities jointly advise against allowing financial undertakings to voluntarily incorporate non-financial counterparties' OpEx KPIs into investment disclosures.p.5
8. The European Supervisory Authorities advise eliminating weighted average group-level KPIs and replacing them with parent undertaking disclosures plus simplified secondary templates.p.5