FFA methodological note on data collection

Scope :

The results reported in this study are based on a survey conducted by the FFA in 2021 on a panel of 22 insurance groups representing 94% of the total assets of French insurance companies at the end of 2020 (general fund coverage rate, life and non-life: 93%; unit-linked coverage rate: 94%). The groups making up the panel are: AG2R La Mondiale, Allianz France, Assurances du Crédit Mutuel, AXA France, AVIVA France, BNP Paribas CARDIF, Crédit Agricole Assurances, CNP Assurances, COVEA, Generali, Groupama, HSBC Assurances vie, MACIF, MACSF, MAIF, Natixis Assurances, SCOR, SMA Group, SOGECAP, Suravenir, SwissLife France and Thelem Assurances. The insurers responded on the situation of their French entities (insurance companies under French law or French subsidiaries of French or foreign groups).

Unless otherwise stated, all data are as of December 31, 2020. The majority of the questions concerned investments in property and life insurance activities via the general fund. A portion of the questionnaire dealt exclusively with investments in unit-linked policies. Please note that funds managed on behalf of third parties are excluded.


Unless otherwise stated, the figures are given as a % of non-unit-linked assets in the tooltips of certain graphs and in the outlooks.

More specifically,

- Data describing the distribution of certain practices are expressed in number of companies and in "% of assets". The denominator then corresponds to the total amount of assets, excluding unit-linked funds, managed by the sample (€2,234bn).

- The values of the investments from the questionnaire were extrapolated to provide indicators for the entire French insurance market. The indicators concerned are : - the amount of green investments, - the coverage rate of assets of insurers with a coal exclusion policy.

- For SRI, Greenfin or Finansol labeled units of account, and exposure to GCEL companies, the amounts communicated correspond to the figures for the market as a whole, calculated from the regulatory statements (S06.02, line-by-line assets). The list of labels corresponds to the list finalized at the end of July 2021. The 2019 values have been recalculated from the latest available lists.

- For the different climate risk assessment methodologies, an average coverage rate is provided. It corresponds to the ratio between the sum of the assets covered by the analysis and the total non-unit-linked assets of the companies that have implemented this analysis.

Definitions :

1) Green Investments

Green Bonds: Green Bonds are bonds issued by companies, local governments, states or international organizations that aim to finance activities with an environmental benefit. Only Green Bonds that have received a second opinion and comply with the Green Bond Principles or Climate Bond Standards are counted.

Green real estate: Green real estate to be counted in this indicator corresponds to assets with environmental certifications (LEED, BREAM, HQE, E+C-, etc.) or BEPOS (BEPOS buildings). Direct real estate investments are (i) directly owned buildings and (ii) real estate companies (SA, SCI, SCPI, OPCI, etc.) in which the insurance company directly or through its parent group controls 90% or more, regardless of the vehicle.

Green funds: funds that have obtained an environmental label (Greenfin, LuxFlag Climate Finance, LuxFlag environnement) or funds that do not have a label but whose name explicitly targets

Green infrastructure: Green infrastructure investments are investments in infrastructure assets or infrastructure entities in the sense of Solvency 2 (see below) that contribute to the transition to sustainable business models, for example renewable energy infrastructure.

Infrastructure assets (Solvency 2): tangible assets, physical structures or equipment, systems and networks that provide or support essential public services;

Infrastructure Entity (Solvency 2): an entity or group of companies that, during the most recent financial year of that entity or group for which figures are available, or on the basis of a financing proposal, derives the majority of its revenue from owning, financing, developing or operating infrastructure assets

These green investments are identified on a declarative basis by the insurers in the panel (representing 93% of general funds, life and non-life) and then extrapolated to the entire market.

Note that this definition is not aligned with the European Taxonomy Regulation (Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework for sustainable investment and amending Regulation (EU) 2019/2088). This is because the regulation was not yet published when the survey was conducted and the technical review criteria will only be finally adopted by the European Commission at the end of 2020 for climate change mitigation and adaptation targets and at the end of 2021 for water, pollution prevention and control, biodiversity and circular economy targets. It was therefore not possible to carry over green investments in the sense of the European Taxonomy for this exercise.

This definition of green investments will therefore evolve in the coming years to align with the criteria of the European Taxonomy.

2) Types of Climate Analysis

Calculating the carbon footprint of a portfolio entails evaluating the greenhouse gas emissions of the companies that constitute the investment portfolio. This indicator provides a static view of the portfolio's footprint at a given moment.

Calculation of a portfolio temperature: a synthetic indicator that attributes the warming temperature scenario if the global economy were to reflect the composition of the portfolio.

Sector Alignment Analysis: methods that assess the alignment of financial portfolios with decarbonisation scenarios for certain key business sectors, generally the sectors most sensitive to transition risks. These methods measure the gap between the carbon intensity recommended by sector to meet the targets of the Paris Agreement and that of companies in the portfolio.

Analysis of the energy or technology mix adequacy: this methodology consists in transposing the challenges of the 2°C carbon budget to a challenge of shifting the energy mix (for energy companies) or technology mix (for car manufacturers). The current and projected mixes are compared with IEA objectives.

3) Exposure to thermal coal

In November 2019, the Fédération Française de l'Assurance (FFA) compiled a list of NGO recommendations deemed relevant by the profession to design an investment strategy for thermal coal.

Coal exposure as reported at the Sustainable Finance Observatory corresponds to the exposure of direct investments by the panel of insurers to companies exceeding the exclusion thresholds recommended at the end of 2020 in this guide, namely :

- relative criteria: share of coal in revenues >30% and/or share of coal in electricity generation >30%.

- Absolute criteria: annual thermal coal production >20 MT or installed capacity >10 GW

- expansion criteria (developers): companies planning new coal mining or extraction operations, new coal-fired power plants or new coal infrastructure

French insurers used the Global Coal Exit List (GCEL) produced by the NGO Urgewald to calculate this exposure at end 2019 and end 2020:

  • An analysis was first carried out by the FFA to assess the exposure of the panel members' direct investments to companies included in the GCEL. For this purpose, all investments corresponding to an ISIN code listed in the GCEL or originating from an issuer associated with an LEI code listed in the GCEL were included in calculations. Investments were taken into account in their entirety: no pro rata was calculated on the basis of revenue share or the proportion of coal in the energy mix of the company benefiting from the investment.
  • These data were then communicated for each separate player, to the panel insurers, to verify, adjust if necessary, the exposure calculated by the FFA.
  • The exposures reported by the panel's insurers were finally extrapolated to communicate a market exposure to thermal coal.

4) Responsible, Green and Inclusive Units of account

This indicator looks at assets in Units of account (French unités de compte) in life insurance contracts meeting the criteria set out in the PACTE law, namely:

- Units of account meeting socially responsible investment criteria and having obtained the SRI label;

- Units of account meeting the criteria for financing the environmental and energy transition and awarded the Greenfin label;

- Inclusion-based units of account that have between 5% and 10% of their assets in securities issued by approved socially responsible companies, venture capital firms or venture capital mutual funds, provided that at least 40% of the assets comprising these funds are made up of securities issued by solidarity-based companies. Although not required by law, some of these funds may carry the Finansol label.

Assets under management were compiled on the basis of declarations by the insurers in the panel (representing 90% of the French market's unit-linked policies) and then extrapolated to the entire market.


The questionnaire completed by insurers is available below.

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