1. EU challenges ahead in conduct of business
William Vidonja, Head of Conduct of Business
Opatija, 10 November 2016

2. Insurance Europe European insurance and reinsurance federation,
Who?
European insurance and reinsurance federation,
founded in 1953
What?
Represents around 95% of European insurance market by premium income
Why?
Committed to creation of favourable regulatory and supervisory framework for insurers at European and international level.

3. Members 34 national associations 27 EU member states 5 non-EU markets
Switzerland, Iceland, Norway, Turkey, Liechtenstein
2 associate members
Serbia, San Marino
1 partner
Russia

4. Contribution to the economy
Insurance Europe represents around European (re)insurers, which:
generate premium income of €1 200bn
directly employ over people
invest nearly €9 800bn in the economy

5. Conduct of business: setting the scene

6. The EU framework in a nutshell
Regulatory and supervisory framework
Level 1
Basic EU legislative act
Level 2
Additional measures for implementing level 1 legislation
Level 3
Consistency in implementation of rules

7. Conduct of business: from the EU… to you

8. EU distribution: Level 1 overview
Applies to non-life and life, including insurance-based investment products (IBIPs)
Includes direct seller
Professional requirements Sales disclosures Advice and non-advised Conflicts of interest Remuneration Product oversight & governance (POG) Cross-selling, etc.
Product disclosures for PRIIPs, including IBIPs
PRIIPs
IDD
COB
Solv. II*
Pre-contractual disclosures for life and non-life
Cancellation right for life insurance
* Solv.II Title II, chapter I, section 5

9. EU distribution: Level 2 overview
DA on POG, conflicts of interest, inducements, suitability and appropriateness
ITS on Insurance product information document (IPID)
RTS on PII
Revised RTS on presentation, contents, delivery and review of the KID
PRIIPs
IDD
COB
Solv. II *
* Solv.II Title II, chapter I, section 5

10. EU distribution: Level 3 overview
Guidelines:
Assessment and supervision of cross-selling practices
Understanding of risk for IBIPs
Assessment of non-complex IBIPs ?
PRIIPs
IDD
COB
Solv. II *
* Solv.II Title II, chapter I, section 5

11. EU distribution: Level 4 overview
Transposition by member states
PRIIPs
IDD
COB
Solv. II *
Detailed rules for implementing information requirements by member states
* Solv.II Title II, chapter I, section 5

12. New data protection rules12

13. Will the intended outcomes be achieved?

14. EU legislation applicable
to the sale of insurance-based investment products (IBIPs)
Disclosure requirements
including duplications (on-line sale by a broker)
Sales disclosures
IMD (9)
Product disclosures
Life directive (20)
Data protection directive (4)
Distance marketing directive (29)
E-commerce directive (17)
Yesterday: 79

15. x4 x3,3 400% 330% EU legislation applicable
IDD (36)
EU legislation applicable
to the sale of insurance-based investment products (IBIPs)
Sales disclosures
400% x4
Disclosure requirements
including duplications (on-line sale by a broker)
PRIIPs regulation (27)
Product disclosures
330%
x3,3
Solvency II directive (39)
Sales disclosures
IMD (9)
Product disclosures
Life directive (20)
General data protection regulation (13)
Data protection directive (4)
Distance marketing directive (29)
Distance marketing directive (29)
E-commerce directive (17)
E-commerce directive (17)
Yesterday: 79
Tomorrow: 161

16. 400% Duplicative rules 330% EU legislation applicable
IDD Standard
EU legislation applicable
to the sale of insurance-based investment products (IBIPs)
Sales disclosures
400%
Duplicative rules
IDD PRIIPs chapter
Duplicative rules
Duplicative rules
PRIIPs regulation (27)
Advice
Duplicative rules
Product disclosures
330%
Costs and charges disclosures
Solvency II directive (39)
Disclosure of similar information
General data protection regulation (13)
Distance marketing directive (29)
E-commerce directive (17)
Tomorrow: 161

17. Information requirements (IBIPs sold by a broker)
119 cumulative disclosures
79 cumulative disclosures
Volume of information
52 cumulative disclosures
20 cumulative disclosures
33 cumulative disclosures
24 cumulative disclosures
1994
2005
2017
1995
2016
2018
3rd Life
Insurance Directive              
Insurance Mediation Directive              
Insurance Distribution Directive + General Data Protection Regulation
Solvency II Directive
Data Protection Directive             
PRIIPs Regulation

18. Insurance Distribution Directive General Data Protection Regulation
Next steps ?
NOW
1 January 2016
Solvency II
1 January 2017
PRIIPs Regulation
1 February 2018
Insurance Distribution Directive
1 May 2018
General Data Protection Regulation

19. The way forward?

20. Consumer-centric insurance regulation
Level 1, Level 2 and Level 3
Assess:
Risk of overregulation
Coherence of regulatory framework
All elements in 1.
PROPOSAL 1 2
Assess impact on product/service:
Price
Access
Choice/diversity
Innovation
Quality/usefulness
Understanding
Comparability
and
Competition
Economy/growth
Etc.
Consumer
cost-benefit
analysis
Cumulative
impact 3
Consider:
Consumer diversity
Change vs stability
EU vs local EU
action? 4
Technology
neutral
Consider:
Digital/ non-digital access
Future-proofing 5
Test in practice:
Understanding/comparability
Quality/usefulness
Value/relevance
Consumer needs/demands
BEST OUTCOME FOR CONSUMERS
Consumer
testing

21. Thank you For more information

22. Consumers at heart
Our interactive web-tool