Sustainability factors should refer to existing categories and the amendments should only apply to products with an investment purpose
- The proposed amendments to 2017/2358/EU should only apply to products with an investment purpose (e.g. insurance-based investment products), not all insurance products. All insurance products include risk insurance products such as home, health or vehicles insurance, where sustainability preferences are often irrelevant.
- Insurance undertakings should not be required to consider sustainability factors in the product approval process of all insurance products, but only if the insurance product is to be advised or sold to customers with sustainability preferences.
- The definition of sustainability preferences should refer to the existing categories of sustainable products in Article 8 and 9 SFDR without adding the further qualifications proposed as sub-points (i) and (ii) of Article 2 (4). It should be possible to take into account the customer’s sustainability preferences also in situations where the customer would prefer a product that promotes environmental or social characteristics even if said product would not fulfil the qualifications set out in sub-points (i) and (ii) of Article 2 (4).
- Finance Finland promotes the response given by Insurance Europe on this topic.