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The Role of Prudential Regulation and Supervision of Insurers in Sustainable Finance

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Sustainable Finance in Europe

Part of the book series: EBI Studies in Banking and Capital Markets Law ((ESBCML))

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Abstract

This chapter addresses the role of prudential supervision in sustainable finance from the insurance sector perspective. The ability of the insurance and reinsurance sector to contribute to the objectives of the sustainable finance agenda, such as its role in the green transition, is closely intertwined with prudential considerations, such as the ability to (continue to) take insurance risk, its exposure to sustainability risk through its investments and its ability to include sustainable investments in its investment portfolio, while safeguarding a prudent level of policyholder protection. The European Commission and society more generally attribute a crucial role to the financial sector in the green transition. This includes certainly the insurance and reinsurance sector and fits within the broader efforts to connect finance with the specific needs of the European and global economy for the benefit of the planet and our society. This chapter focuses on the manner in which the prudential challenges, connected to sustainable finance, are addressed for the insurance and reinsurance sector, in particular through the Solvency II framework. A key role in respect of sustainability risks is attributed to the Own Risk and Solvency Assessment (ORSA), a crucial element within Solvency II. To the extent risks are not captured by solvency capital requirements, they might be captured, at least partly, by the ORSA that takes a longer-term perspective to the capital needs of insurance and reinsurance undertakings than the capital requirements do, which is a relevant notion in relation to sustainability risk.

Furthermore, as institutional investors, insurance and reinsurance undertakings may represent an important source of funding for the sustainable transition. While, certainly under Solvency, insurance and reinsurance undertakings enjoy freedom of investment, they are, at the same time, bound by the prudent person principle, which compels them to invest in the primary interest of policyholders and beneficiaries. In addition, investment and underwriting risk should be reflected in the capital requirements. Therefore, it is crucial that insurance and reinsurance undertakings are conscious of the risks they accept, be it through their underwriting activities or through their investments. In recent years, significant efforts have been made to make progress in this respect, initially within the existing Solvency II framework, which has been designed in essence as agnostic to the types of risks and should therefore be capable of addressing sustainability risks as well, and gradually as well through amendments to the Solvency II Delegated Regulation, focusing on pillar 2 requirements and gradually exploring ways to incorporate sustainability in pillar 1 as well, including in capital requirements. In particular in this last area, further efforts are still required to appropriately capture sustainability risks, while maintaining a sound prudential framework for insurance and playing a significant role in the sustainability transition.

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Notes

  1. 1.

    See in more detail on the European Commission’s Sustainable Finance Action Plan and the renewed Sustainable Finance Strategy: Ingrid van der Klooster and Arthur van den Hurk, Chapter 2.

  2. 2.

    See https://www.unepfi.org/insurance/insurance/.

  3. 3.

    As phrased by Achim Steiner, United Nations Under-Secretary-General and Executive Director, United Nations Environment Programme in the foreword to the UNEP FI report: “The global state of sustainable insurance Understanding and integrating environmental, social and governance factors in insurance”: “The insurance industry has long been in the vanguard of understanding and managing risk and has served as an important early warning system for society by amplifying risk signals. Through loss prevention and mitigation, by sharing risks over many shoulders, and as major investors, the insurance industry has protected society, shaped markets and underpinned economic development.” See https://www.unepfi.org/fileadmin/documents/global-state-of-sustainable-insurance_01.pdf.

  4. 4.

    Message from the UNEP FI Insurance Working Group and its Academic Working Group in the UNEP FI report: “The global state of sustainable insurance understanding and integrating environmental, social and governance factors in insurance”: “better understand the impacts of environmental, social and governance (ESG) factors on the insurance business and sustainable development, and how to unleash the immense capacity of the insurance industry to manage ESG risks and uncover the opportunities these entail. We believe that the capacity of the insurance industry to address global sustainability issues—as risk managers, risk carriers and institutional investors—is underestimated. We believe that the industry itself, given the complexity of the insurance business and the industry structure, is not fully understood by its stakeholders. Equally, we recognize major challenges confronting a highly fragmented, competitive, and regulated industry that impede the integration of ESG factors at the company level, the varying degrees of impact that ESG factors can have across core insurance processes and lines of insurance, and the collective industry action needed to robustly tackle ESG factors at the national, regional and global levels.” See https://www.unepfi.org/fileadmin/documents/global-state-of-sustainable-insurance_01.pdf.

  5. 5.

    IAIS, May 2021, Application Paper on the supervision of climate-related risks in the insurance sector, https://www.iaisweb.org/uploads/2022/01/210525-Application-Paper-on-the-Supervision-of-Climate-related-Risks-in-the-Insurance-Sector.pdf.

  6. 6.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final, 8 March 2018.

  7. 7.

    European Commission, Strategy for Financing the Transition to a Sustainable Economy (COM) 2021 390 final, July 6, 2021.

  8. 8.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), paragraph 3.3.

  9. 9.

    European Commission, Action Plan: Financing Sustainable Growth, COM(2018) 97 final (8 March 2018), paragraph 3.2.

  10. 10.

    Typically, the ORSA takes into account a time horizon of 3 to 5 years. Solvency II distinguishes two solvency requirements. The Minimum Capital Requirement (MCR) corresponds to a level of eligible own funds below which policyholders and beneficiaries would be exposed to an unacceptable level of risk (while still maintaining a level of assets, sufficient to cover the insurance liabilities). The (higher level of) solvency capital requirement (SCR) is the level of capital requirements that insurance and reinsurance undertakings are expected to meet at least. In addition, they are expected to avoid frequent breaches of their SCR. Typically insurance and reinsurance undertakings maintain own funds at a level well above the SCR. The SCR is calculated on the basis of a Value at Risk (VaR) of 99,5% over a one-year time horizon, which clearly does not capture climate risk that might materialize over a longer time horizon.

  11. 11.

    ESMA’s technical advice to the European Commission on integrating sustainability risks and factors in MiFID II, Final Report (ESMA 35-43-1737), April 30, 2019, https://www.esma.europa.eu/sites/default/files/library/esma35-43-1737_final_report_on_integrating_sustainability_risks_and_factors_in_the_mifid_ii.pdf and EIOPA’s Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and IDD (EIOPA-BoS-19/172), April 30, 2019, https://register.eiopa.europa.eu/Publications/EIOPA-BoS-19-172_Final_Report_Technical_advice_for_the_integration_of_sustainability_risks_and_factors.pdf.

  12. 12.

    It should be noted that the prudent person principle has both quantitative and qualitative characteristics and therefore is both a pillar 1 and pillar 2 topic.

  13. 13.

    Directive (EU) 2016/97 of the European Parliament and of the Council of 20 January 2016 on insurance distribution, Official Journal EU 2016, L 26/19.

  14. 14.

    The amendments to the IDD-framework are not discussed in detail in this chapter. See further V. Colaert, Chapter 17.

  15. 15.

    Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities, Official Journal EU 2009 L 302/32.

  16. 16.

    Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010, Official Journal EU 2011 L174/1.

  17. 17.

    Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU, Official Journal EU 2014 L 173/349.

  18. 18.

    See in more detail: V. Colaert, Chapter 17.

  19. 19.

    EIOPA Opinion on Sustainability within Solvency II EIOPA-BoS-19/241, September 30, 2019, https://register.eiopa.europa.eu/Publications/Opinions/2019-09-30%20OpinionSustainabilityWithinSolvencyII.pdf.

  20. 20.

    https://eiopa.europa.eu/Publications/Requests%20for%20advice/signed_letter_28_08_18.pdf.

  21. 21.

    EIOPA Opinion on the supervision of the use of climate change risk scenarios in ORSA, April 19, 2021, EIOPA-BoS-21/127, after the consultation of a draft supervisory Opinion, published on October 5, 2020: https://www.eiopa.europa.eu/content/eiopa-consults-supervision-use-climate-change-scenarios-orsa.

  22. 22.

    EIOPA Application guidance on running climate change materiality assessment using climate change scenarios in the ORSA, August 2, 2022, EIOPA-BoS-22/329.

  23. 23.

    https://www.eiopa.europa.eu/system/files/2021-07/methodological_paper-potential-inclusion-of-climate-change-in-the-natcat-standard-formula.pdf, preceded by the publication of a discussion paper on that topic on December 2, 2020.

  24. 24.

    Furthermore, EIOPA notes that this first analysis is subject to various limitations.

  25. 25.

    EIOPA sensitivity analysis of climate change-related transition risks, December 15, 2020, https://www.eiopa.europa.eu/system/files/2020-12/sensitivity-analysis-climate-change-transition-risks.pdf.

  26. 26.

    EIOPA, European insurers’ exposure to physical climate change risk, potential implications for non-life business, May 20, 2022, EIOPA-BoS-22/278, https://www.eiopa.europa.eu/system/files/2022-05/discussion_paper_on_physical_climate_change_risks.pdf; EIOPA and ECB, Staff Paper on Policy options to reduce the climate insurance protection gap, April 24, 2023, https://www.eiopa.europa.eu/system/files/2023-04/ecb.policyoptions_EIOPA~c0adae58b7.en_.pdf.

  27. 27.

    EIOPA and ECB, Staff Paper on Policy options to reduce the climate insurance protection gap, April 24, 2023, pp. 2–3.

  28. 28.

    EIOPA, Discussion paper on the Prudential Treatment of Sustainability Risks, November 29, 2022, EIOPA-BoS-22/527. This discussion paper was followed by a consultation paper, published on December 13, 2023, on the prudential treatment of sustainability risks, https://www.eiopa.europa.eu/consultations/consultation-prudential-treatment-sustainability-risks_en.

  29. 29.

    EIOPA, Methodological paper on the potential inclusion of climate change in the Nat Cat standard formula, June 29, 2021, EIOPA-BoS-21/253. As of 2020, initially in pilot form, EIOPA also publishes a yearly dashboard on the insurance protection gap on natural catastrophes, https://www.eiopa.europa.eu/tools-and-data/dashboard-insurance-protection-gap-natural-catastrophes_en. On 3 April, 2024, EIOPA has launched a public consultation on reassessing natural catastrophe risk in the Solvency II standard formula that insurers (unless they use an internal model) use to calculate their solvency capital requirement (SCR), https://www.eiopa.europa.eu/consultations/consultation-20232024-reassessment-natural-catastrophe-risk-standard-formula_en.

  30. 30.

    EIOPA Opinion on Sustainability within Solvency II EIOPA-BoS-19/241, September 30, 2019, https://register.eiopa.europa.eu/Publications/Opinions/2019-09-30%20OpinionSustainabilityWithinSolvencyII.pdf, paragraphs 4.40–4.42.

  31. 31.

    EIOPA’s Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and IDD, EIOPA-BoS-19/172, April 30, 2019, p. 19, https://www.eiopa.europa.eu/system/files/2020-01/technical_advice_for_the_integration_of_sustainability_risks_and_factors.pdf.

  32. 32.

    As discussed in paragraph 1.2.2.2.3.

  33. 33.

    Article 260 of the Solvency II Delegated Regulation.

  34. 34.

    For readability purposes, I will refer only to insurance undertakings in the remainder of this chapter.

  35. 35.

    EIOPA Opinion on the use of climate change risk scenarios in the ORSA, April 19, 2021, EIOPA-BoS-21/127.

  36. 36.

    EIOPA, Application guidance on the running climate change materiality assessment and using climate change scenarios in the ORSA, August 2, 2022, EIOPA-BoS-22/329.

  37. 37.

    In the meaning of article 29 of Regulation (EU) 1094/2010.

  38. 38.

    Commission Delegated Regulation (EU) 2017/2358.

  39. 39.

    EIOPA Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and the IDD, April 30, 2019, EIOPA-BoS-19/712, paragraph 114, 23.

  40. 40.

    EIOPA Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and the IDD, April 30, 2019, EIOPA-BoS-19/712, paragraph 115, 23.

  41. 41.

    EIOPA Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and the IDD, April 30, 2019, EIOPA-BoS-19/712, paragraph 115, 23.

  42. 42.

    Recital 71, Directive 2009/138/EC.

  43. 43.

    Article 135(1) sub a of the Solvency II Directive.

  44. 44.

    Commission Delegated Regulation (EU) 2021/1256, dated April 21, 2021.

  45. 45.

    Article 2, Commission Delegated Regulation (EU) 2021/1256.

  46. 46.

    For the purpose of efficient portfolio management, not for speculative purposes, see also EIOPA: What are the requirements that shall be met by the transactions on derivatives to be considered as facilitating effective portfolio management by the undertaking? What are the types of transactions on derivatives that cannot be considered as facilitating effective portfolio management, EIOPA Q&A 1388, July 23, 2018.

  47. 47.

    Article 132(2) 3rd paragraph Solvency II Directive.

  48. 48.

    Recital 25, Solvency II Directive.

  49. 49.

    Recital 16, Solvency II Directive.

  50. 50.

    Such as in UCITS funds or internal funds held by insurance undertakings.

  51. 51.

    Article 132(3) of the Solvency II Directive.

  52. 52.

    Also, EIOPA expects insurers to avoid as possible underlying of investment-based investment products, instruments for which ESMA has issued a ban or restriction. In 2018 EIOPA issued a statement in this respect aimed at policyholder exposures to contracts for differences and binary options: EIOPA, Statement on consumer detriment resulting from policyholder exposure to contracts for differences and binary options, June 1, 2018, EIOPA-18/215. In the statement, EIOPA points at the product intervention powers that national competent authorities and, additionally, EIOPA have at their disposal, but the statement also has clear links to the application of the prudent person principle in this case in respect of assets underlying PRIIPs.

  53. 53.

    Article 133(3) of the Solvency II Directive. The restrictions may not be more stringent than those set out in Directive 85/611/EEC (UCITS Directive).

  54. 54.

    Article 132(2) 3rd paragraph refers to “the security, quality, liquidity and profitability of the portfolio as a whole.” This appears to be consistent with the application of the prudent person rule pursuant to the IORP Directive, see, e.g. R. Maatman, Prudent- person regel en verantwoord beleggingsbeleid, Tijdschrift voor Ondernemingsbestuur, 2007, no. 6.

  55. 55.

    The EIOPA Guidelines on the system of governance provide some high-level guidance, but in EIOPA, Final Report on public consultation no. 14/017 on Guidelines on the system of governance, January 28, 2015, EIOPA-BoS-14/253, paragraph 2.13, EIOPA acknowledges that it would be premature to provide extensive guidelines on the prudent person principle at that point in time. Accordingly, EIOPA has limited the guidelines to very basic minimum requirements reminding undertakings that greater flexibility for investments is linked with firm responsibilities on the governance around the investment activities, and that the level of prudence required is not diminished under Solvency II.

  56. 56.

    Final report, paragraph 2.142.

  57. 57.

    EIOPA Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and the IDD, April 30, 2019, EIOPA-BoS-19/712, paragraphs 102–106.

  58. 58.

    Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088, Official Journal EU L 198/13.

  59. 59.

    EIOPA Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and the IDD, April 30, 2019, EIOPA-BoS-19/712, paragraph 110.

  60. 60.

    See paragraph 5.1, in which it is described how EIOPA suggests such an approach can be shaped.

  61. 61.

    Directive (EU) 2016/2341 of the European Parliament and of the Council of 14 December 2016 on the activities and supervision of institutions for occupational retirement provision, Official Journal EU 2016 L 354/37.

  62. 62.

    Article 19(1) b of Directive (EU) 2016/2341.

  63. 63.

    See in particular: EIOPA, Technical Advice for the review of the IORP II Directive, September 28, 2023, EIOPA-BoS-23/341, https://www.eiopa.europa.eu/system/files/2023-09/EIOPA-BoS-23-341-Advice_IORPII_review.pdf.

  64. 64.

    EIOPA Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and the IDD, April 30, 2019, EIOPA-BoS-19/712, paragraph 113.

  65. 65.

    Art. 275a paragraph 2 of the Solvency II Delegated Regulation.

  66. 66.

    Commission Delegated Regulation (EU) 2021/1257, OJ L 227/18. These amendments are discussed in more detail by V. Colaert in Chapter 17.

  67. 67.

    Paragraph 91 of the final compromise text introduces the new Article 304a with three mandates to EIOPA as regards sustainability risks. EIOPA is mandated to explore by 2023 a dedicated prudential treatment of exposures related to assets or activities associated substantially with environmental and/or social objectives, and assets and activities associated substantially with harm to such objectives including fossil fuel related assets and to review regularly the scope and the calibration of parameters of the standard formula pertaining to natural catastrophe risk. In addition, as proposed by the Council, EIOPA will have to evaluate to what extent insurance and reinsurance undertakings assess their material exposure to risk related to biodiversity loss as part of the ORSA (art. 304 (2a) final compromise text of the Solvency II Directive, published on January 24, 2024, see reference in footnote 68). 

  68. 68.

    Council of the European Union, Interinstitutional file: 2021/0295 (COD), January 19, 2024, Confirmation of the final compromise text with a view to agreement, https://www.data/consilium.europa.eu/doc/document/ST-5481-2024-INIT/en/pdf.

  69. 69.

    EIOPA Staff Paper on nature-related risks and impacts for insurance, March 27, 2023, EIOPA-23-247, https://www.eiopa.europa.eu/system/files/2023-03/EIOPA%20Staff%20paper%20-%20Nature-related%20risks%20and%20impacts%20for%20insurance.pdf.

  70. 70.

    European Parliament briefing on the proposal amending the Solvency II Directive, https://www.europarl.europa.eu/RegData/etudes/BRIE/2023/739314/EPRS_BRI(2023)739314_EN.pdf. See further, art. 1a of the final compromise text, as published on January 24, 2024 (reference included in footnote 68). Article 1a amends article 19a (6) of the Accounting Directive (2013/34/EU) in this respect.

  71. 71.

    Technical trialogue meetings continued in the beginning of 2024.

  72. 72.

    Article 41 of the Solvency II Directive.

  73. 73.

    Article 304a of the final compromise text for the Solvency II Directive of January 24, 2024, see reference in footnote 68.

  74. 74.

    EIOPA, Prudential Treatment of Sustainability Risks, Discussion Paper, November 29, 2022, EIOPA-BoS-22/527. This discussion paper was followed by a consultation paper, published on December 13, 2023, on the prudential treatment of sustainability risks, https://www.eiopa.europa.eu/consultations/consultation-prudential-treatment-sustainability-risks_en.

  75. 75.

    Reference can be made as well to the ongoing work at international level of the IAIS on the same topic, from both micro- and macro-prudential perspectives. See in particular recently the IAIS Draft Application Paper on climate scenario analysis in the insurance sector, November 2023, https://www.iaisweb.org/uploads/2023/11/Draft-Application-Paper-on-climate-risk-scenario-analysis-in-the-insurance-sector.pdf.

  76. 76.

    EIOPA: Opinion on the supervision of climate change risk scenarios in the ORSA, April 19, 2021, EIOPA-BoS-21/127, https://www.eiopa.europa.eu/system/files/2021-04/opinion-on-climate-change-risk-scenarios-in-orsa.pdf.

  77. 77.

    EIOPA, Application guidance on climate change materiality assessments and climate change scenarios in ORSA, August 2, 2022, EIOPA-BoS-22/329, https://www.eiopa.europa.eu/system/files/2022-08/application_guidance_on_running_climate_change_materiality_assessment_and_using_climate_change_scenarios_in_the_orsa_0.pdf.

  78. 78.

    For example, Dutch Central Bank, Q&A on climate risks for insurers, February 2, 2021; and Dutch Central Bank, Good Practice on the treatment of climate-related risks on the ORSA, November 4, 2019.

  79. 79.

    Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector, Official Journal EU 2019 L 317/1.

  80. 80.

    EIOPA Staff Paper on nature-related risks and impacts for insurance, March 27, 2023, EIOPA-23-247, https://www.eiopa.europa.eu/system/files/2023-03/EIOPA%20Staff%20paper%20-%20Nature-related%20risks%20and%20impacts%20for%20insurance.pdf.

  81. 81.

    Article 304a of Solvency II Directive final compromise text, publised on January 24, 2024, see reference in footnote 68.

  82. 82.

    See EIOPA Revised single programming document 2023–2025, including Annual Work Programme 2023, September 29, 2023, EIOPA-BoS-22/460, which includes the following actions: (1) assess the prudential treatment under Solvency II of assets and activities associated substantially with environmental and social objectives or which are associated substantially with harm to such objectives (subject to the deadline in the final version of Solvency II) and (2) initiate reassessment of the natural catastrophe risk standard formula capital charges (Q4 2024).

  83. 83.

    Motivated by the proposed mandate in article 304a of the Solvency II Directive, pursuant to the Commission Proposal of September 22, 2021.

  84. 84.

    EIOPA, Prudential Treatment of Sustainability Risks, Discussion Paper, November 29, 2022, EIOPA-BoS-22/527.

  85. 85.

    EIOPA acknowledges that, while the prudential analysis should be risk based and policy implications evidence based, ESG data gaps are a constraining factor for the scope of the prudential analysis, Chapter 1, paragraph 6 of the discussion paper.

  86. 86.

    EIOPA, Prudential Treatment of Sustainability Risks, Discussion Paper, November 29, 2022, EIOPA-BoS-22/527, paragraph 7. This discussion paper was followed by a consultation paper, published on December 13, 2023, on the prudential treatment of sustainability risks, https://www.eiopa.europa.eu/consultations/consultation-prudential-treatment-sustainability-risks_en.

  87. 87.

    At the occasion of the launch of the EIOPA Dashboard, that depicts the insurance protection gap for natural catastrophes across Europe, EIOPA Dashboard on insurance protection gap for natural catastrophes, December 5, 2022.

  88. 88.

    EIOPA, Impact Underwriting, Report on the Implementation of Climate-Related Adaptation Measures in Non-Life Underwriting Practices, February 6, 2023, EIOPA-BoS-22-593, https://www.eiopa.europa.eu/system/files/2023-02/Impact%20underwriting%20-%20Report%20on%20the%20implementation%20of%20climate-related%20adaptation%20measures%20in%20non-life%20underwriting%20practices.pdf.pdf.

  89. 89.

    Communication from the Commission to the European Parliament, the Council, the European Economic and Social committee and the Committee of the regions, Strategy for Financing the Transition to a Sustainable Economy, July 6, 2021, COM(2021) 390 final.

  90. 90.

    https://climate.ec.europa.eu/eu-action/adaptation-climate-change/climate-resilience-dialogue_en.

  91. 91.

    https://www.eiopa.europa.eu/tools-and-data/dashboard-insurance-protection-gap-natural-catastrophes_en.

  92. 92.

    European Commission, Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937, February 23, 2022, COM(2022) 71 final. See also the compromise text of the CSDDD, published subsequent to the agreement reached in the COREPER meeting on 15 March 2024. The CSDDD is expected to be adopted in its final form after the 2024 European Parliament elections.

  93. 93.

    It should be noted that, regardless of the CSDDD, undertakings subject to the CSRD will have to report on their climate change transition plan.

  94. 94.

    In addition, as mentioned above, EIOPA has launched a discussion on initial considerations for a prudential treatment for climate-related transition risks, where data seem to be most advanced at this stage, EIOPA, Discussion paper on the Prudential Treatment of Sustainability Risks, November 29, 2022, EIOPA-BoS-22/527.

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  1. A.S.R. Nederland N.V, Utrecht, The Netherlands

    Arthur van den Hurk

  2. Financial Law Centre (FLC), Radboud University Nijmegen, Nijmegen, The Netherlands

    Arthur van den Hurk

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Editors and Affiliations

  1. Financial Law Centre (FLC), Radboud University Nijmegen, Nijmegen, The Netherlands

    Danny Busch

  2. Department of Law, University of Genoa, Genoa, Italy

    Guido Ferrarini

  3. Financial Law Centre (FLC), Radboud University Nijmegen, Nijmegen, The Netherlands

    Seraina Grünewald

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van den Hurk, A. (2024). The Role of Prudential Regulation and Supervision of Insurers in Sustainable Finance. In: Busch, D., Ferrarini, G., Grünewald, S. (eds) Sustainable Finance in Europe. EBI Studies in Banking and Capital Markets Law. Palgrave Macmillan, Cham. https://doi.org/10.1007/978-3-031-53696-0_10

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