Insurance Mediation

The customer must be able to compare

Transparency and consumer protection for the mediation of insurance products: The European Commission intends to amend the rules for insurance mediation (IMD2 Directive). From GDV’s perspective the disclosure of costs arising from the distribution and conclusion of an insurance contract must have a clear added value for the customer.

For customers to compare and assess insurance products they need to be aware of all costs. But the mediator’s commission, which the European Commission wants to disclose, is only a part of the total costs – a serious comparison between the products is still impossible for the customer. The proposal of the European Commission on the transparency and the mechanisms of fees for the insurance mediation are unsuitable to facilitate the customer’s decision making process.

Since 2008, German insurers disclose the total costs of life- and health insurances. In Germany, the cost structure is thus more transparent than the Commission’s proposal would provide for.  The German transparency requirements for property and casualty insurance are also deemed adequate by GDV. The customer can already compare and assess the products by means of the promised insurance coverage in relation to the premiums.

With view to consumer protection, the proposed option of sale of insurance products without professional advice, is viewed very critically by the GDV. The principles of the first Directive on insurance mediation (IMD1) should be maintained. Accordingly, consultation advice must be obligatory. Selling insurance contracts without prior professional consultation should only be possible in exceptional cases.

The GDV’s complete position paper is available in the download section.


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Position Paper

on the proposal for a Directive of the EU Commission on insurance mediation (re cast) of 3 July 2012