The comments are focused primarily on the aspect of environmental, social and governance (ESG) data, which is the priority for the industry given existing issues with the availability, reliability and comparability of ESG data for investors. It is important that the wider scope beyond ESG data does not slow down the availability of ESG data within the ESAP.
Non-financial data is particularly relevant when ambitious and fast-paced policy actions rely on its availability, as is the case for sustainable finance. Robust, comparable and reliable environmental, social and governance (ESG) data is also vital for identifying and assessing sustainability risks in insurers' activities and is necessary to enable investors, such as insurers, to steer their portfolios towards sustainability objectives: eg the ambitions of the Paris Agreement and of the European Green Deal.
The first priority should be to include the ESG data relating to the Taxonomy Regulation and the Non-Financial Reporting Directive (NFRD), Sustainable Finance Disclosure Regulation (SFDR), and EU taxonomy. As another building block the register should include relevant ESG information already collected by European and national institutions such as governments, central banks, statistical bodies, etc. Member states are already reporting environmental expenditure under the System of Environmental Economic Accounting (SEEA 2012). The EU should open up its databases that collect environmental reporting data and make those re-usable.
The ESAP could also help to minimise related costs for participants, as they would no longer be forced to rely on third-party providers for ESG data. In addition, it can help to improve transparency about ESG data and enhance the comparability and reliability of research and ratings.