EU Taxonomy Underwriting KPI: EIOPA Narrows the Denominator

On 30 October 2026 the European Insurance and Occupational Pensions Authority (EIOPA) sent the European Commission its final advice on (re)insurance disclosures under the Taxonomy Disclosures Delegated Act, Commission Delegated Regulation (EU) 2021/2178. Its core is the EU Taxonomy underwriting KPI that non-life insurers and reinsurers publish in their annual report. EIOPA wants one method for splitting premiums in the numerator, a denominator cut back to the eight Taxonomy-eligible lines of business, and a new name: the Adaptation Underwriting KPI. It also proposes replacing the combined KPI with a single reference KPI and, jointly with the EBA and ESMA, rebuilding group-level Taxonomy reporting around the parent undertaking.

The advice has no legal effect on its own. The Commission’s call for advice says its services aim to complete the review of the Disclosures Delegated Act by Q1 2027, with entry into force in Q3 2027. The numbers would still move once the Commission acts. EIOPA’s own impact assessment puts the excluded share of today’s denominator at around 30%, so reported alignment ratios would rise without any change in the insured book, and the comparative line in the first annual report under amended rules would need explaining.

Related reading: EU Taxonomy Disclosures: EBA Advises Dropping Two Bank KPIs

Dates on the EU Taxonomy underwriting KPI review calendar

• 4 March 2026: DG FISMA’s call for technical advice to the three European Supervisory Authorities (ESAs) on certain Taxonomy KPIs and other aspects of the Disclosures Delegated Act, reference Ares(2026)2366154.
• 1 July 2026: EIOPA opened its public consultation on the insurance proposals. The final advice records 19 responses.
• 28 to 30 October 2026: the three final reports arrive. The EBA submitted its report with a letter dated 28 October, ESMA’s report is dated 29 October and EIOPA’s advice 30 October.
• Q1 2027: the Commission services’ target for completing the review of the Disclosures Delegated Act, with entry into force aimed for Q3 2027.
• 31 December 2027: the transitional relief for Taxonomy reporting that the Omnibus Delegated Act gives financial undertakings expires. The Commission’s call sets the review to land before that date.

The 2027 dates are planning statements in a call for advice. EIOPA’s advice proposes no application date and no transitional arrangement for the changes it recommends. The only forward date it does set concerns a KPI it wants kept out: EIOPA advises the Commission to refrain from introducing a Green Insured Activities KPI in the 2027 review and to revisit the idea in five years.

The baseline insurers report against today

Article 8 of the Taxonomy Regulation, Regulation (EU) 2020/852, requires undertakings subject to sustainability reporting under Articles 19a or 29a of the Accounting Directive to disclose how their activities line up with the Taxonomy. The Disclosures Delegated Act sets the content. For (re)insurers, the Climate Delegated Act, Delegated Regulation (EU) 2021/2139, recognises non-life insurance and reinsurance of climate-related perils (activities 10.1 and 10.2 of its Annex II) as enabling activities that can contribute substantially to climate change adaptation. Eight Solvency II non-life lines of business are eligible.

From that base, EIOPA’s advice summarises four disclosures:

• The underwriting KPI, calculated by (re)insurers other than life insurers, showing what share of non-life gross premiums written (or insurance revenue) is Taxonomy-aligned, presented in the Annex X templates of the Disclosures Delegated Act.
• An eligibility ratio alongside it.
• The investment KPI, a weighted average of investments directed at or associated with Taxonomy-aligned activities, under Annex IX.
• The combined KPI, a weighted average of the investment and underwriting KPIs, used to measure exposures to insurance undertakings.

The split-premium rule comes from Commission guidance. Commission Notice C/2024/6691 of 8 November 2024, FAQ 67, clarifies that for multi-risk products the Taxonomy-aligned underwriting numerator uses only the premium share attributable to climate-related perils. It calls for an appropriate allocation methodology, such as one used in pricing, and specifies non-eligible treatment with a zero numerator where the necessary contract-level premium data cannot be obtained. Insurers first reported these figures at the beginning of 2024, for financial year 2023.

The Omnibus Delegated Act, Delegated Regulation (EU) 2026/73, was published in the Official Journal on 8 January 2026. The Malta Financial Services Authority’s circular of 13 January 2026 records that it applies from 1 January 2026, while issuers may keep applying the earlier versions of the Delegated Acts for financial years starting in 2025. As EIOPA describes it, the amendment changed four things for insurers:

• a 10% de minimis threshold: an insurer may skip the eligibility and alignment assessment for gross premiums written (or non-life insurance or reinsurance revenue) whose cumulative amount stays below 10% of the underwriting KPI denominator, with a parallel 10% test for investments whose use of proceeds is known;
• exclusion from financial-undertaking KPI denominators of derivatives, cash and cash equivalents, on-demand interbank loans, goodwill and commodities; and exclusion of exposures to undertakings outside the relevant Articles 19a and 29a sustainability-reporting scope, subject to the specific SPV exception and permitted inclusion of certain exposures to voluntary reporters or exposures whose use of proceeds is known;
• simplified templates with fewer breakdowns;
• deletion of the dedicated fossil gas and nuclear templates, with certain elements moved into the general templates of financial undertakings.

The de minimis rule is narrower than its nickname suggests. Premiums below the threshold escape the assessment, and the Delegated Act still requires them to be reported separately as non-material gross premiums written or non-material revenue. The Omnibus round replaced Annex X, yet EIOPA still describes the underwriting KPI’s denominator as all non-life business. The Commission’s call invited EIOPA to explore a revised methodology for the underwriting KPI and to propose other targeted improvements where relevant; the eight-line denominator is one of the changes EIOPA advises in response.

What EIOPA found in insurers’ published KPIs

EIOPA analysed a sample of 2024 annual reports from the non-life (re)insurers with the highest gross written premiums under Solvency II: 15 undertakings for the underwriting KPI and 16 for the investment KPI. On average, about 3% of premiums covered by the underwriting KPI were Taxonomy-aligned, about 17% eligible but not aligned, and about 80% non-eligible. Turnover-based and CapEx-based investment alignment both averaged below roughly 5%.

The eligibility ratios told a different story. Sampled companies headquartered in Germany and Austria reported eligibility above 50% and 30% respectively, while the rest stayed below 20%. Alignment stayed below 10% in every jurisdiction in the sample. EIOPA traces the spread to method, and it lists the competing approaches:

• counting all eight lines of business as eligible once at least one product in each line covers climate-related perils, directly or indirectly;
• counting only the gross written premiums of products in the eight lines whose terms and conditions explicitly cover climate-related risks;
• counting all premiums whose terms do not explicitly exclude climate-related perils.

A few companies combine these. The premium split adds a second layer of divergence. Commission Notice C/2024/6691, FAQ 67, addresses premium splitting primarily for the Taxonomy-alignment numerator, and its only eligibility rule is that premiums are reported as non-eligible where the data needed to identify the climate-peril premium share cannot be obtained. EIOPA identified divergent eligibility-calculation practices among insurers: some insurers split premiums for the eligibility ratio, others use full premiums, and some do not say which they did.

Reinsurers raised a separate problem. Their contracts bundle lines of business, territories and perils, so premiums are not recorded at the peril level the Taxonomy expects, and the split relies on model-based proxies, client data and third-party models.

EIOPA also looked at Solvency II natural catastrophe data for the fire and other damage to property line, drawn from reporting under Implementing Regulation (EU) 2023/894. In 2023, 37% of reporting undertakings in that segment said their natural catastrophe products embedded risk-prevention measures, 52% said they did not and 10% said the question did not apply. The 2024 split was 37%, 53% and 9%. Provisional 2025 data show 29%, 55% and 16%, figures EIOPA says are incomplete and subject to revision. The dataset covers more products than the Taxonomy-compliant ones and only one line of business, so it approximates the picture and cannot be read as an alignment figure.

The numerator: one split-premium method for both ratios

EIOPA advises the Commission to clarify in Annex IX that, for both the eligibility ratio and the alignment ratio, the numerator includes only the portion of gross written premium (or insurance revenue) attributable to climate-related perils, and only for contracts or products that cover climate-related perils in one of the eight eligible lines of business. For alignment, the contracts must also meet the criteria in Sections 10.1 and 10.2 of Annex II to the Climate Delegated Act.

The advice names a method. Insurers should use a technical pricing approach: identify, within the total gross written premium charged under the contract, the portion that reflects the pricing of climate-related perils. EIOPA describes this as particularly suitable where pricing systems already break premiums down by peril or risk component. Reinsurers may instead determine the natural catastrophe share through actuarial modelling or established pricing practices, which matters most where a treaty spans several lines, territories and perils. Whatever the route, the advice expects it to be documented, applied consistently over time and appropriate to the nature of the business.

The biggest change for many teams sits on the eligibility side. Today, an insurer that counts the full premium of every eligible contract in its eligibility numerator is within the range of practice EIOPA observed. Under the advice, the eligibility numerator would use the same peril-level allocation as the alignment numerator. On the writer’s reading, that pulls eligibility numerators down for the insurers in the broader camps, at the same time as the denominator shrinks, so the net movement in the eligibility ratio depends on the book.

EIOPA weighed and rejected the simpler alternative of putting the full premium of any product with a Taxonomy-aligned component into the numerator. The advice says that option would overstate alignment where only a small share of the product meets the criteria, invite product design aimed at the ratio and reduce comparability. Most consultation respondents accepted keeping the split as a pragmatic choice because they had already built systems around it, while many industry respondents repeated that it understates insurers’ contribution to adaptation.

The denominator: eight eligible lines of business

Under current requirements, the denominator of both underwriting ratios is all non-life business, measured by gross written premiums or (re)insurance revenue. Lines that can never be eligible, general liability among them, dilute the ratio. EIOPA advises limiting the denominator to the gross written premiums (or insurance revenue) of all contracts in the eight lines of business that the Climate Delegated Act defines as eligible:

• medical expense insurance;
• income protection insurance;
• workers’ compensation insurance;
• motor vehicle liability insurance;
• other motor insurance;
• marine, aviation and transport insurance;
• fire and other damage to property insurance;
• assistance.

It also gives the Commission a fallback. Under the alternative, the denominator would mandatorily contain the three lines the advice identifies as most relevant to climate change adaptation (other motor; marine, aviation and transport; fire and other damage to property), and each insurer could add any combination of the remaining five at its discretion, depending on their relevance to natural catastrophe coverage.

The last row is the option most consultation respondents asked for, together with making the disclosure voluntary. EIOPA kept the eight-line approach, arguing that a three-line denominator would create a discrepancy with the Climate Delegated Act and weaken the incentive to develop aligned products in the other five lines.

EIOPA’s impact assessment expects the eight-line denominator to exclude roughly 30% of today’s denominator. It calls the operational cost minor, since the underlying data is usually already available, and flags the consequence for users: a visible jump in alignment percentages and a break in the historical series, which it says will need clear contextual reporting to explain. For an unchanged book and method, the rise in the alignment ratio comes from re-basing alone.

A name that states the scope: Adaptation Underwriting KPI

EIOPA’s case for renaming the indicator is that the current label does not tell investors what it measures. The only non-life insurance activities listed as environmentally sustainable in the Taxonomy relate to climate change adaptation, and the KPI captures nothing else. Calling it the Adaptation Underwriting KPI is meant to make that limit visible.

EIOPA itself names the weakness. The name stops fitting if the Commission ever lists insurance activities under other environmental objectives. Under the CSRD, insurers already disclose contributions outside adaptation, such as pay-as-you-go motor products or circular practices in claims management, and EIOPA notes that consistency between the two sets of disclosures, usually in the same annual report, would be beneficial. Teams preparing sustainability statements under the revised ESRS will recognise the overlap.

Expanding the range of underwriting activities treated as environmentally sustainable sits outside EIOPA’s mandate, and the advice records that the review of the technical screening criteria for (re)insurance activities is outside the scope of the call.

A reference KPI in place of the combined KPI

The combined KPI in point 1(e) of Annex IX blends Taxonomy-aligned underwriting revenue with Taxonomy-aligned turnover or CapEx of investments. EIOPA’s verdict is that it lacks economic rationale because it mixes liabilities with assets. Some insurers raised the same objection in their annual reports, arguing that a weighted average of assets and liabilities is not meaningful.

The advice proposes that composites report both KPIs in the annual report, and that insurance-led financial conglomerates do the same. For users who need one number, such as investors measuring exposure to insurers in Green Investment Ratio disclosures or in product disclosures under the Sustainable Finance Disclosure Regulation, the annual report would identify a reference KPI. That KPI is one of the existing two, chosen by which activity generates more gross written premiums:

EIOPA chose gross written premiums because it is a flow measure of new and renewed business for both life and non-life. Its analysis of 2025 Solvency II data from quantitative reporting template (QRT) S.05.01 found that a majority of composites wrote more non-life than life premium, with a smaller but significant group the other way round. Two alternatives were dropped: net revenue built from Solvency II templates, which can swing with markets, and technical provisions, a stock measure that accumulates over decades in life business and would overstate life’s weight in a composite.

The three-year review is the operational detail composites should note. A composite whose life and non-life premiums are close would hold its reference KPI for three years instead of switching with each year’s premium mix. The advice does not say when the first determination would be made or which year’s premiums it would use.

Gas and nuclear rows, and no OpEx for financial undertakings

EIOPA advises removing the breakdown of fossil gas and nuclear activities from both the investment and the underwriting templates. For underwriting, the breakdown has no application: the screening criteria, do no significant harm test and minimum safeguards for non-life insurance have nothing to do with nuclear or fossil gas activities. For investments, EIOPA found the information mostly non-material for the largest insurers, and it links the removal to the materiality approach the Omnibus Delegated Act introduced in 2026. Industry respondents supported the change.

The Omnibus round had already deleted the dedicated gas and nuclear templates while moving certain elements into the general templates of financial undertakings. On the writer’s reading, EIOPA’s recommendation targets that remaining breakdown, so a team with an open change request to rebuild gas and nuclear rows in its insurance templates has a reason to pause it.

On the horizontal OpEx question, the three ESAs jointly advise against allowing financial undertakings to use the OpEx KPI of investee non-financial undertakings, even voluntarily, and particularly in the investment KPI of (re)insurers. Their reasons: the Taxonomy OpEx definition differs from operating costs in management accounts, it requires a separate reconciliation, and financial undertakings and investors told the ESAs they do not generally rely on it. This answer covers financial undertakings’ KPIs only. The OpEx KPI that non-financial companies report is a separate topic, covered in ESMA’s final report under the same call, and the insurer investment KPI would stay Turnover-based and CapEx-based.

Group reporting built on the parent undertaking

The Disclosures Delegated Act sets templates for each type of undertaking but, outside the credit institution regime, says little about groups that mix them. The Commission filled the gap in its third Commission Notice, C/2024/6691 of 8 November 2024. As EIOPA cites it, FAQs 7, 9 and 11 have the parent of a mixed group or financial conglomerate disclose, within the contextual information under Annex XI, a group KPI calculated as a turnover-weighted average of its activities’ KPIs, and report the templates for each activity type, such as Annex X for (re)insurance, consolidated at business level.

The ESAs report that this can produce double counting and ratios that combine different calculation bases. EIOPA’s own review of insurance activities in groups found heterogeneous practice: most insurer-led groups publish the insurance KPIs specified by Annex IX using the Annex X templates in their consolidated statements, with investment metrics more mature than underwriting ones, while some banking-led groups disclosed the insurance investment KPI and no underwriting KPI at all.

The joint ESA advice removes the weighted-average group KPI and builds group disclosures from two elements:

1. A main reporting regime set by the type of parent undertaking. If the group is a financial conglomerate under Directive 2002/87/EC, the KPIs are those relevant to the undertaking leading the conglomerate. A financial holding that is not a conglomerate follows a dedicated regime where one exists, such as the one for financial holding companies as defined in Article 4(1), point (20), of Regulation (EU) No 575/2013, and the non-financial rules where none does.
2. Simplified disclosures for subsidiaries whose secondary activities fall outside the main KPIs, differ in nature from the parent’s activity, represent a significant share of the group’s activities and do not exclusively serve the group’s internal needs.

EIOPA adds three points of its own. The annual report should identify the parent’s KPI as the figure for measuring exposure to the group, for example in SFDR investment disclosures or in a Green Investment Ratio, and for insurance parents that figure is the reference KPI. Materiality of a subsidiary should be judged by what users such as investors need. Subsidiaries that exclusively serve the group, such as captive (re)insurers or internal financial service providers, should be exempt.

For material (re)insurance subsidiaries, EIOPA drafts two simplified templates that can be filled subsidiary by subsidiary or on a consolidated basis. The underwriting version, for non-life or composite subsidiaries, carries absolute premiums for year t and the proportion of premiums for years t and t-1, across rows for Taxonomy-aligned, Taxonomy-eligible and Taxonomy-non-eligible activities. The investment version, for life or composite subsidiaries, carries the proportion of Taxonomy-eligible investments, the proportion of Taxonomy-aligned investments, the assets covered by the KPI and the aligned investments of the previous period, each on a Turnover basis and a CapEx basis.

One drafting point is open. The simplified underwriting template totals to total non-life gross premiums written, while the advice narrows the full KPI’s denominator to the eight eligible lines. The advice does not reconcile the two bases; that is left to the Commission’s drafting.

The Green Insured Activities KPI is parked for five years

The Commission’s call floated a different underwriting metric: a KPI showing how much non-life business covers Taxonomy-aligned companies and assets, designed like the KPIs of other financial institutions. EIOPA’s consultation paper explored it as the Green Insured Activities KPI and drafted a methodology. The final advice recommends against introducing it and proposes revisiting the concept in five years, with the consultation paper’s methodology as a possible starting point.

EIOPA’s reasons are cost, method and data. Data on insured businesses outside the EU, in the retail sector, on SMEs and on entities not reporting under the Taxonomy would be hard to obtain, and EIOPA notes these would need to be excluded from the ratio. Most respondents opposed the extra metric. The impact assessment borrows banking-sector estimates to size the burden: one-off IT and system costs of EUR 1 million to EUR 5 million (from the EBA’s March 2021 advice on Article 8 disclosures), EUR 100,000 to EUR 150,000 for third-party ESG data, three to eight additional full-time equivalents for a large financial group (from the Commission’s 2021 impact assessment) and audit cost increases of 15% to 25% (from banking industry estimates). These are proxies drawn from the GAR experience, and EIOPA presents them as such.

On EIOPA’s advice, the look-through question moves to the next review cycle. The decision on the 2027 amendment, including whether any insured-counterparty data requirement is adopted, rests with the Commission, which receives the ESAs’ advice as input and drafts the legal text itself.

Preparing the data before the Commission drafts

The advice imposes nothing, so these are preparatory steps a reporting team can take to shorten its response once a draft amendment appears. Each maps to a recommendation above.

1. Peril-level premium split. Identify which pricing systems already produce a premium breakdown by peril or risk component, since that is where EIOPA’s technical pricing approach fits. Where they do not, write down the allocation method in use today; reinsurers can do the same for their modelling approach.
2. Line-of-business tagging. Tag gross written premiums (or insurance revenue) by the eight eligible Solvency II lines and run a pro forma ratio under both the eight-line denominator and the three-plus-five alternative. That quantifies the jump the annual report would need to explain.
3. Eligibility numerator test. Compare the current eligibility method with the advice: contracts covering climate-related perils in the eight lines, with the climate-peril share split out.
4. Reference KPI check for composites. Compare life and non-life gross written premiums, the same basis EIOPA used from QRT S.05.01, to see which KPI would become the reference KPI.
5. Group perimeter. List subsidiaries whose activities sit outside the parent’s KPIs and do not serve only the group. Those are the candidates for simplified templates; captives would fall under the proposed exemption.

A team that rebuilds its templates now on the strength of the advice risks building to an option the Commission does not adopt. The Commission can take the primary recommendation, the alternative or neither, and the subsidiary template question above shows that drafting choices remain.

For the sister work on bank KPIs and the July consultations that fed all three reports, see the EBA’s advice on bank Taxonomy KPIs and our note on the July 2026 Taxonomy consultations.

Frequently Asked Questions

Will the advice change our financial year 2026 Taxonomy disclosure?

The advice itself does not. The Commission’s target is adoption in Q1 2027 with entry into force in Q3 2027, and no published document yet fixes the financial year from which an amended Disclosures Delegated Act would apply. Until an amending act specifies its application date, Annexes IX and X of Delegated Regulation (EU) 2021/2178, as amended by Delegated Regulation (EU) 2026/73, remain the applicable detailed rules. Article 7(9) of that Regulation also permits qualifying financial undertakings to use a temporary opt-out until 31 December 2027 where they make no claims under Articles 3 and 9 of the Taxonomy Regulation that their activities are associated with environmentally sustainable economic activities and disclose the information referred to in Article 8(1) of the Taxonomy Regulation by including the prescribed statement in their management report.

Would the narrower denominator change our 10% non-material threshold test?

The advice does not address the interaction. Under the Omnibus Delegated Act, as EIOPA summarises it, the 10% test is measured against the denominator of the underwriting KPI. My reading is that if the Commission narrows that denominator to eight lines, the base for the 10% test would narrow with it, so premiums that fall under the threshold today could exceed it afterwards. That depends on how the Commission drafts both provisions.

We are a primary insurer and our pricing system does not split premiums by peril. Does the advice give a fallback?

Not explicitly: the technical pricing approach is described as particularly suitable where systems already give a peril-level breakdown, and the model-based route is described for reinsurers. Separately from EIOPA’s proposed changes, Commission Notice C/2024/6691, FAQ 67, already provides that insurers should use an appropriate methodology, such as one based on pricing, to identify premiums attributable to climate-related perils. Where the necessary data cannot be obtained for a contract, its premiums should be reported as non-eligible and a zero value entered in the underwriting KPI numerator. Any different future treatment would depend on further Commission action or clarification.

Our group is bank-led with an insurance subsidiary. Whose KPIs lead?

Under the joint ESA advice, the main reporting regime follows the parent, so a bank-led group reports on the credit institution basis. If the group is a financial conglomerate, the KPIs are those relevant to the undertaking leading it. The insurance subsidiary’s simplified templates would appear only if its activities meet the conditions for material secondary activities. EIOPA’s review found some banking-led groups disclosing the insurance investment KPI with no underwriting KPI, and suggests this may reflect a judgment that the non-life activity was not material, or reliance on the proportionality and materiality points in the Commission’s guidance.

Does the captive exemption remove a captive’s own reporting obligation?

No. The proposed exemption concerns simplified disclosures within a group’s reporting. Whether a captive (re)insurer reports on its own account depends on whether it is itself within the scope of Articles 19a or 29a of the Accounting Directive, which the advice does not change.

Does the advice change Solvency II supervisory reporting?

No change to Solvency II templates is proposed. EIOPA uses QRT S.05.01 premium data as evidence for the reference KPI criterion and natural catastrophe data from Solvency II reporting as context. Because Solvency II already reports premiums by line of business, those figures are a natural reconciliation point for the line-of-business tagging the advice would require, an inference on my part, since the advice does not prescribe a data source.

Is EIOPA’s advice the only input the Commission has on insurer KPIs?

Among the three ESA reports, yes for the insurance-specific KPIs: the call assigned the underwriting KPI to EIOPA. Group reporting and the use of OpEx were horizontal issues coordinated across the ESAs. The EBA’s covering letter states the same two positions, and ESMA’s report covers both topics in its own chapters.

Related Articles

• EU Taxonomy Disclosures: EBA Advises Dropping Two Bank KPIs: the EBA’s parallel final report on bank KPIs, GAR templates and grandfathering under the same call.
• EU Taxonomy Disclosure Simplification: The 12 August ESMA Deadline: the July 2026 consultations by ESMA, the EBA and EIOPA that fed into the final advice.
• Revised ESRS: The 60% Datapoint Cut Facing CSRD Reporters: the CSRD sustainability statement in which insurers’ Taxonomy disclosures sit.
• EIOPA Private Equity Insurers: The Evidence Supervisors Should Request: EIOPA’s October 2026 supervisory statement on private-equity-backed insurers.

Key Takeaways

• FY2026 reporting is governed by Delegated Regulation (EU) 2021/2178 as amended by Delegated Regulation (EU) 2026/73, subject to the conditional Article 7(9) opt-out for qualifying financial undertakings that make no Taxonomy-alignment claims and publish the prescribed statement. The Commission intends to adopt further amendments in Q1 2027, but that timetable remains a planning target.
• Size the jump before it appears: an eight-line pro forma ratio shows how much of the expected rise is re-basing alone.
• An eligibility numerator built on full premiums would fall under the advice, independent of the denominator change; quantify that effect separately from the re-basing.
• Composites near a 50/50 premium mix gain from modelling both reference KPI outcomes, because the choice would hold for three years.
• A planned rebuild of gas and nuclear rows in the insurance templates is a candidate to pause until the Commission’s text appears.
• Before investing further in a turnover-weighted group KPI, weigh the ESAs’ advice to replace it with the parent’s KPI, which for insurer-led groups is the reference KPI.
• EIOPA recommends against introducing a Green Insured Activities KPI in the forthcoming amendment and proposes revisiting the idea in five years. This is advice and not a binding decision; the Commission will determine whether any new KPI or associated data requirement is adopted.

Sources and References

• EIOPA, news release, “EIOPA publishes its final advice on enhancements to insurers’ corporate disclosures under the EU Taxonomy”, 30 October 2026: eiopa.europa.eu
• EIOPA, “Advice to the Commission on the review of (re)insurance disclosures under the Taxonomy Disclosures Delegated Act”, 30 October 2026, publication page: eiopa.europa.eu; PDF: Final Advice (PDF)
• EIOPA, consultation on the review of insurance disclosures under the Taxonomy Disclosures Delegated Act (opened 1 July 2026): eiopa.europa.eu
• European Commission, DG FISMA, Call for technical advice to the ESAs on certain Taxonomy KPIs and other aspects of the Disclosures Delegated Act, Ref. Ares(2026)2366154, 4 March 2026: Call for Advice (PDF)
• EBA, letter to DG FISMA submitting the EBA Final Report on Taxonomy disclosures, 28 October 2026: EBA letter (PDF)
• ESMA, Final Report on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act, ESMA32-846262651-5927, 29 October 2026: ESMA Final Report (PDF)
• Regulation (EU) 2020/852 (Taxonomy Regulation), Article 8: EUR-Lex
• Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act), Annexes IX and X: EUR-Lex
• Commission Delegated Regulation (EU) 2021/2139 (Climate Delegated Act), Annex II, Sections 10.1 and 10.2: EUR-Lex
• Commission Delegated Regulation (EU) 2026/73 of 4 July 2025 (Omnibus Delegated Act), OJ 8 January 2026: EUR-Lex
• Malta Financial Services Authority, Circular “Publication of the Amended Delegated Act of the EU Taxonomy Regulation in the EU Official Journal”, 13 January 2026: MFSA Circular (PDF)
• Commission Notice C/2024/6691 of 8 November 2024 (third notice on Article 8 reporting by financial undertakings), FAQs 7, 9, 11 and 67: EUR-Lex
• Directive 2013/34/EU (Accounting Directive), Articles 19a and 29a: EUR-Lex
• Directive 2002/87/EC (Financial Conglomerates Directive): EUR-Lex
• Regulation (EU) No 575/2013 (CRR), Article 4(1), point (20): EUR-Lex
• Commission Implementing Regulation (EU) 2023/894 (Solvency II reporting templates): EUR-Lex

Next document to watch: the Commission’s draft amendment to Annex IX

All three ESA reports are now with the Commission. The next primary document for insurers is the Commission’s draft amendment to Delegated Regulation (EU) 2021/2178, targeted for adoption in Q1 2027. When it appears, check three provisions first: the Annex IX numerator wording, the denominator option chosen, and the application date for the first financial year.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.