Insurance distribution

The European Commission is reviewing the 2002 EU Insurance Intermediation Directive (IMD) with a view to enhancing consumer protection, introducing a level regulatory playing field between distribution channels and improving conduct of business rules for insurance intermediaries.

The CEA believes that minimum harmonisation – ie, EU legislation that sets minimum requirements that member states have to meet when implementing the legislation into national law — is the best way to accommodate the existing diversity in insurance distribution markets in the EU.

The CEA also believes that regulation must be proportionate to the type of distribution channel concerned. It proposes high-level principles to govern selling practices that could be modulated to reflect the distribution channel, the demands and needs of the customer, the complexity of the product and the level of risk to the consumer.

The CEA supports the EC's objectives of enhancing consumer protection by addressing potential conflicts of interest and has proposed possible ways to achieve this objective.