Insurance Europe agrees with the European Insurance and Occupational Pensions Authority (EIOPA) that for insurers' key performance indicators the alignment with taxonomy-aligned activities should be assessed based on non-life gross premiums and the assessment of funding taxonomy-aligned economic activities should be based on the investments.

While agreeing with EIOPA the industry also has some important concerns about the technical details of EIOPA's advice.

The industry input to the European Commission (EC) makes a number of proposals for improvements and clarifications which would ensure the indicators work in practice and provide a fair and useful view of an insurer's contribution to sustainable activities. These include clarifying a feasible implementation timeline, the need for the investments KPI to be based on eligible assets and consistent across financial sectors, and for the underwriting KPI to be at the product level.

The sector disagrees with the EIOPA advice that all investments should be included in the "investments" ratio. Only Taxonomy eligible investments should be considered rather than taking all investments into account. EIOPA mentions that insurers should use "expert judgement and approximations" to be used until the Taxonomy criteria can be applied to such investments, but this will result in confusion, lack of comparability and inconsistencies with the approach recommended by other supervisors.