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The advice will feed into the Commission’s proposals for its review
of the EU Retail investment Strategy (RIS), which has the potential to
significantly impact the insurance industry and its consumers. It is,
therefore, vital that the specific nature of the insurance sector and
the products it offers are considered in any legislative proposals.
Given
that EIOPA acknowledges that the Insurance Distribution Directive (IDD)
provides a solid and appropriate framework for the distribution of
insurance, priority must be given to maintaining the overall current
rules and coupling them with targeted improvements where needed.
Insurance
Europe welcomes a number of EIOPA’s proposals that represent a
pragmatic step towards a simpler consumer journey, such as the long
overdue elimination of duplicative disclosure requirements and the
introduction of more digital-friendly rules for consumer disclosures. As
to any further initiatives on disclosures, extensive testing on
consumers must be conducted by the EU institutions to ensure they lead
to clear improvements for all products in scope and do not confuse
consumers further.
Moreover, any new proposals must be
proportionate. Rules should always be designed to meet the needs of
consumers while not being overly burdensome for insurers. This is
because additional legal requirements generally lead to increased costs
for insurers and ultimately their consumers.
It is also
important to note that the IDD was deliberately designed as a minimum
harmonisation Directive to allow the necessary flexibility to consider
local market structures and consumer behaviour. Access to advice, for
consumers who would benefit from it, is vital in all markets to increase
consumer participation and trust in capital markets. Measures taken
under the RIS should, therefore, not restrict consumers’ ability to
access affordable high-quality advice by working within existing market
structures. While EIOPA’s proposals to streamline the advice and sales
process are welcome, more work is needed to ensure this is appropriate
for both on and offline sales, and does not result in an inferior
service being provided to consumers.