Conduct of business/Consumer protection


Policyholder protection, in particular that of consumers, is a key element of the EU’s insurance regulatory system.

Conduct of business legislation aims to ensure fairness, transparency and clear communication between insurance purchasers and providers. The main dossiers include the Insurance Distribution Directive and the Package Retail and Insurance-based Investments Products (PRIIPs) Regulation that applies to insurance-based investment products. The current legislative agenda includes the potential application of a minimum harmonisation Insurance Guarantee Schemes regime.

The mutual/cooperative insurance model places policyholders at the centre of all their activities. In particular, consumers are actors that energise the people-orientated mutual approach to insurance. As recognised stakeholders within a mutual, policyholders are not simply seen as “clients”: the relationship means that they have a direct stake and say in how the mutual/cooperative insurer  operates.

It is vital that the rules developed by the policymaking community provide the appropriate treatment to ensure that mutual/cooperative insurance concerns can conduct their business in the best interests of their policyholders/members.

AMICE highlights the need to ensure that any requirements are fit for a digital age so that a policyholder is able to choose between paper-based and digitally-based communications.

Serious questions are being asked about whether a minimum harmonisation of insurance guarantee schemes is required and feasible. The robust nature of the Solvency II regulatory regime has proved the tolerance of the insurance sector; additional requirements for guarantee schemes would be complex and create a further burden which ultimately would be borne by the policyholder.

Position Papers