Over the summer and coming into September 2025, Invest Europe responded to several European Commission consultations on Solvency II rules, the Capital Requirements Regulation (CRR), Supplementary Pensions, Climate Resilience and on the Merger Guidelines. The consultations reflect the importance given to our industry and our association is making a strong effort to push forward regulatory changes that will encourage long-term investment, innovation, and growth in the EU.
In our response to the Solvency II technical rules review, we recommend that changes are introduced to the technical rules allowing insurers to include all non-substantially leveraged long-term equity funds in their long term equity portfolios, subject to lower risk weights. This change is crucial to increase insurers’ participation in long-term equity investment, unlocking much-needed capital to support EU innovation and sustainable growth.
In our response to the CRR consultation, Invest Europe warned that a prompt revision of CRR rules was needed to better distinguish between direct equity investments and diversified fund exposures, ensuring risk weights better reflect the actual risk involved.
In our response to the IORP II review, we raise concerns around the barriers that prevent European pension funds from investing in private equity, venture capital, and other alternatives at scale. IORP has long deterred investments in alternative assets. We call for clearer guidance to encourage proportionate, risk-based investment rules that support long-term growth aligned with pension funds’ liabilities. There is a real opportunity to unlock additional pension capital in venture capital, infrastructure and private equity.
In our response to the European Commission’s call for evidence on climate resilience and risk management, Invest Europe highlights the growing importance of climate adaptation alongside mitigation – from both a business and economic perspective. We underline the increasing demand for resilient infrastructure and climate-smart technologies, which present new opportunities for economic growth. At the same time, we point to key challenges including the absence of clear taxonomies, the complexity of measuring impact, and gaps in policy support. We recommend stronger coordination between EU and national instruments, capital charge incentives, and reformed procurement rules to help mobilise private investment in climate resilience projects across Europe. This submission is part of Invest Europe’s broader engagement through the Climate Resilience Reflection Group.
In our response to the merger guidelines consultation, Invest Europe recommends updates that better reflect the unique nature of private equity transactions. We propose expanding safe harbours and clarifying market share thresholds to reduce unnecessary and costly reviews of deals involving non-controlling or minority interests common in private equity portfolios. We highlight that private equity firms usually do not have incentives to limit competition because their portfolio companies are managed separately. These changes would provide greater legal certainty, improve regulatory efficiency, and support the flow of investment that benefits EU competitiveness.
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