The insurance industry is Europe's largest institutional investor, with EUR 10 trillion of assets under management, and for insurers to make appropriate investment decisions and comply with sustainability regulation it is vital that consistent, comparable, and machine-readable sustainability data is available, the recent Insurance Europe's survey says.

The CSRD (Corporate Sustainability Reporting Directive) together with the European Single Access Point initiative can achieve this. The survey provides updated key messages on the EC's proposals for the CSRD and points out such important improvements needed for the CSRD as consolidated reporting, multiphase delivery of standards, assurance, SME definition which works for insurance.

The findings of the survey include the following (as well as proposed solutions):

• The definition of SME undertakings included in the draft text does not work for insurers;
• The decision to move to reasonable assurance should not be automatically linked to the 2 development of standards on reasonable assurance;
• The option to report at consolidated (group) level must apply to public interest entities (PIEs) 3 as it does for others;
• It is vital that any delays (such as those under discussion by co-legislators) do not apply to data needed to meet mandatory reporting requirements (e.g. SFDR and Taxonomy) - standards for this data are needed by 2023 so the data can be reported from 2024;
• The timelines for mandatory reporting should be set relative to the availability of standards rather than fixed with a date in the Directive to allow for the possibility of delays in finalizing the standards.