Insurance Distribution Directive update
Dutch senate adopts IDD implementing law
The law implementing IDD in the Dutch Financial Supervision law (Wet op het financieel toezicht) was adopted by the Dutch senate (Eerste Kamer) on 6 March 2018. In this publication we provide you with an update of recent developments regarding the Insurance Distribution Directive (IDD).
Recent regulatory developments
It is already two years ago that IDD was adopted to replace the Insurance Mediation Directive. In addition, delegated regulations on product oversight (EU 2017/2358) and the distribution of insurance based investment products (EU 2017/2359) were adopted, next to an implementing regulation on the insurance product information document (EU 2017/1469).
IDD was scheduled to apply as of 23 February 2018. However, on 14 February 2018 an agreement was reached to delay the transposition deadline and postpone the application deadline to 1 October 2018. This means an extension of the application deadline of seven months.
In the Netherlands, the law implementing IDD in the Dutch Financial Supervision law (Wet op het financieel toezicht) was adopted by the Dutch senate (Eerste Kamer) on 6 March 2018. It is expected the law will apply as of 1 October 2018.
What is IDD?
The key objectives of the IDD are to protect customers and to ensure fair competition within the insurance market; as well as to create a level playing field in the European market between every insurance distributor and intermediary.
To achieve these objectives IDD contains provisions on the following key topics:
- Product Oversight and Governance
Specific requirements apply on the product approval process and exchange of information between insurance company and distributors
- Insurance Product Information Document
A detailed standardized document for non-life insurance products
- Suitability and Appropriateness assessment for Insurance Based Investment Products
For Insurance-Based Investment Products a suitability/appropriateness assessment is introduced based on MiFID II requirements
- Continuous Professional Development
Competency and continuous professional development is to be ensured by insurance companies and intermediaries
- Conflicts of Interest and Inducements
Specific requirements apply on policies and procedures relating to conflicts of interest
If an ancillary product or service, which is not insurance based, is offered together with an insurance product, specific requirements apply on information to be provided to the customer
How can we help you?
Deloitte leverages experience in the market and its international network to help your organization. We can support you with:
- Performing a quick scan to assess what the current state is of your IDD gap analysis or stage of implementation;
- Training and development of your employees in order to understand and work with the IDD requirements;
- Performing a gap analysis, in which the IDD requirements will be compared with your current processes and supporting information systems. Workshops and interviews will be held to support this analysis, after which you gain insight into the level of compliance and the required follow-up actions;
- Defining appropriate target markets and grouping customers accordingly;
- Determining what cost structure information has to be shared with the customer and utilizing analytical capabilities to create further insight into the cost structure of products;
- The development of the Insurance Product Information Document for your products;
- Developing frameworks to facilitate assessment of suitability of a product for an individual client.