There is strong support in the insurance industry for the Commission to require investee companies to directly report transparent Environmental, Social and Governance (ESG) data/assessments. This will help address issues with the availability and quality of data that would hinder insurers' work to comply with their regulatory obligations in relation to ESG data.
The revised NFRD should be consistent with the requirements of the disclosures and taxonomy regulations to ensure investors have all the data they need to comply efficiently and consistently. Data and relevant assessments should be published in a standardised data format and available electronically in a way that allows access and minimises the cost for investors and other users of the information. To significantly increase efficiency, ease of access and to reduce costs, the ESG data should be made available in a centralised database/electronic register.
The materiality of disclosures and proportionality considerations need to be included explicitly in any non-financial reporting standard to avoid an excessive financial and operational burden on smaller companies. Any requirements which would go beyond what is required to comply with the disclosures and taxonomy regulations should only be included if the benefits outweigh the costs.