IIF Response to EIOPA Consultation Paper on Greenwashing

The IIF urges regulators to adopt a precise definition of greenwashing focused on misrepresentation, ensuring it targets actual deception rather than broader market conduct issues already covered by existing laws. This distinction is crucial for preventing overly broad regulations that could mislabel legitimate business practices as environmental fraud. Furthermore, the industry stresses the importance of preserving insurers' autonomy in product design and pricing based on risk. By resisting regulatory interference in these commercial decisions, insurers can maintain solvency and accurately reflect market signals, ensuring that supervision only intervenes when verified consumer harm occurs. This discourse is relevant to greenwashing because it highlights the tension between defining fraudulent intent and regulating general market behavior. Clarifying this boundary prevents the dilution of the greenwashing concept, ensuring that enforcement actions remain targeted at genuine misrepresentations rather than punishing standard insurance risk management and pricing strategies.

Source: iif.com
Published on 2024-03-13

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