insurer asks who our main customers are, should I mention names

Customer concentration is different from customer names

Usually, an insurer does not ask for the names of your largest customers, but for your customer concentration: what share of your revenue comes from your largest customer(s). This is a risk assessment for the insurer, not a client investigation as a bank conducts under the Money Laundering Prevention and Financing of Terrorism Act. With a bank, a question about counterparties may be related to client due diligence on the organization itself; with an insurer, it is almost always about continuity risk. Therefore, the same type of question carries different weight at a bank than at an insurer — it is not the same question with a different logo on top.

If names are nevertheless asked for literally, this is usually optional or can be replaced by a percentage or a category ("largest customer is X% of revenue", "sector: automotive"). Customer names are not included in the group file as a fixed source — there is no legal obligation that requires this, unlike, for example, the obligation to file annual accounts. If you still want to provide a figure without mentioning the names yourself, a percentage of revenue is usually sufficient. If you are uncertain whether a specific answer is privacy-sensitive or competition-sensitive, there is a confidentiality button to make that answer visible only to the party requesting it.

Why this is separate from UBO and annual account data

The Commercial Register Act 2007 stipulates which data of a business are public and mandatory — think of the data from filed annual accounts and the structure of ultimate beneficial owners. Customer names are not among these. The Money Laundering Prevention and Financing of Terrorism Act obliges a bank or insurer to conduct client due diligence on their own customer — this is an investigation that the institution conducts, not an answer that the entrepreneur must provide about their own customers. Directive (EU) 2022/2464 (CSRD) touches on supply chain reporting on sustainability, but does not require the naming of individual customer names either. Because there is no source document for this specific question, there is also no fixed answer that can be presented as "yes" — this remains a manual assessment for each questionnaire.