Legal environment

COVID-19 legislation

A great deal of pandemic-related European and national legislation was enacted in 2021 and existing legislation from 2020 was extended in order to control and mitigate the effects of the COVID-19 pandemic. This also had significant effects on VIG Holding and the Group. In Austria, for example, the amendment to corporate law was maintained to the effect that board meetings could also be held without the physical presence of the participants. In addition, the deadlines for holding general meetings and preparing annual financial statements as well as notification deadlines under Austrian insurance supervisory law and in court and administrative proceedings were extended (again). Labour and tax regulations for home offices were also further standardised. Legal changes with respect to customer areas, workplaces and events, and the lockdown restrictions had a significant impact on VIG Holding and its subsidiaries.

Sustainable finance

The European Commission aims to make Europe the first climate-neutral continent in the world by 2050 under its “European Green Deal” initiative. In 2021, this political objective became legally binding on all Member States and therefore indirectly applicable to VIG Holding and the VIG

Group under European Climate Law. A number of directly applicable European regulations were adopted from 2019 to 2021 to achieve this goal, in particular the so-called “Taxonomy Regulation” and “Disclosure Regulation”. The first creates a system for classifying environmentally sustainable activities and represents a voluntary minimum standard for classifying VIG Holding and Group investments and non-life insurance premiums starting as of 1 January 2022. The second applies to Group companies that offer insurance-based investment products and includes pre-contractual and periodic information duties to make disclosures at both the company and product levels with respect to sustainability risks and the adverse sustainability impacts of investments for all life insurance policies concluded on or after 10 March 2021.

Digital resilience

Regulating the digital security of the financial sector was also a focus of attention at the European level during the reporting period. In September 2020, the European Commission published a legislative proposal for a Digital Operational Resilience Act (DORA) that is aimed at requiring financial market participants to implement all the security measures needed to mitigate cyberattacks and other risks. Based on current information, it is not expected to be applicable before 2023.


The Trade and Cooperation Agreement concluded by the EU and United Kingdom at the end of 2020 formally came into force on 1 May 2021. It is mainly a free-trade agreement for goods and services. It also includes a number of provisions concerning cooperation in other areas (e.g. the coordination of social security, law enforcement and judicial cooperation). With respect to direct insurance, the loss of the freedom to provide services means the possibilities for offering and providing reciprocal services are now very limited. Some countries have therefore adopted transitional arrangements. With respect to reinsurance, it remains to be seen whether the European Commission will reach a decision on the equivalence of supervisory regimes and therefore whether reinsurance companies with registered offices in the United Kingdom are to be treated the same as those with registered offices in the European Union.