Q&As

Does the Insurance Distribution Directive apply to insurance intermediaries distributing only general insurance products (ie no insurance-based investment products)? What is the process for conflicts of interest for insurance intermediaries distributing only general insurance products (ie no insurance-based investment products)? What is the process for conflicts of interest for insurance intermediaries distributing insurance-based investment products?

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Published on: 26 September 2018
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Insurance Intermediaries: conflicts of interest and the Insurance Distribution Directive (IDD)

This Q&A addresses how insurance intermediaries should handle conflicts of interest following implementation of Directive (EU) 2016/97, the Insurance Distribution Directive (IDD).

The IDD applies from 1 October 2018. It is not directly applicable and is implemented by the Insurance Distribution (Regulated Activities and Miscellaneous Amendments) Order 2018, SI 2018/546. Its primary aim is to enhance consumer protection when buying insurance, including general insurance, life insurance and insurance-based investment products (IBIPs). It thus applies to insurance intermediaries who distribute any type of insurance product. Nonetheless, the IDD imposes more prescriptive obligations specifically on IBIP distribution so as to align customer protection in this area more closely with MiFID II; see, in particular, Delegated Regulation (EU) 2017/2359 which

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