Insurance Europe: Insurers welcome repeal of DMD, but warn on unintended consequences of remaining provisions
26 October 2022
Insurance Europe strongly welcomes the repeal of the DMD but recommends transferring its remaining provisions to more recent sector-specific EU legislation, such as the Insurance Distribution Directive.
Insurance Europe has published a set of key messages regarding the repeal of the EU’s Directive on Distance Marketing of Consumer Financial Services (DMD).
It is also important for policymakers to:
- Ensure
legal certainty and avoid duplication of requirements, such as
disclosures, should the remaining provisions be transferred to the
Consumer Rights Directive.
- Avoid unintended detrimental
consequences resulting from the introduction of a new withdrawal button,
as, for example, consumers may find themselves inadvertently uninsured.
- Remove
the requirement for pre-contractual information at least one day before
the time at which the consumer is bound by any distance contract. This
is at odds with consumers’ expectations of speedy and easy purchasing
processes in an increasing digital world, and their needs for immediate
insurance coverage, for example when travelling or renting a car.
- Remove
the requirement to always be able to obtain human intervention as it
would not be compatible with digital developments. For example, chatbots
are available 24/7 and requiring human intervention to also be
available 24/7 would be extremely burdensome.
- Provide insurers
with sufficient transposition time: for example, a minimum of six months
from the end of the implementation period.
Insurance Europe
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