ShareAction has submitted a response to the consultation on the EU’s Solvency II Delegated Regulation, a key piece of legislation that sets how insurers calculate their capital requirements and manage risks.

We express our concern that the current direction risks weakening insurers’ financial resilience and overall financial stability, while failing to ensure that freed-up capital supports the EU’s green transition. We also make key recommendations for the European Commission, notably to implement EIOPA's 2024 recommendation for higher capital requirements for insurers’ investments in risky fossil fuel assets.