On 30 January 2014, EIOPA published its report on good practices for comparison websites (here), in response to EIOPA’s consultation on this topic. The report is concerned primarily with the activities of commercial comparison websites, as opposed to non-commercial websites run by consumer and/or industry associations or public authorities. Although the report itself states that the good practices are not intended to be legally binding and are not “comply or explain” guidelines, EIOPA expects the good practices to be adopted on a voluntary basis.
The report is concerned with six main areas:
- Market coverage – EIOPA considers it good practice to disclose how many products the website compares per type of policy, the number of insurance undertakings whose products are compared, and their names, communicate on the market coverage transparently and in a way that is easy for internet users to locate and understand, and clearly detail the criteria used by the comparison website on how it has selected the insurance undertakings.
- Dealing with potential conflicts of interest – EIOPA considers it good practice to disclose those providers with whom a comparison website has a commercial, contractual or ownership relationship, and to explain the meaning if “Editor’s choice”, “product of the week”, “most popular”, “best buys” features and the information on which these are based.
- Criteria used to make the ranking – EIOPA considers it good practice to ensure a consistent listing of product features, not use price as the sole criterion for comparison, enhance the list of criteria, when necessary (for example, the more complex a product, the more criteria may need to be taken into consideration when comparing products), and if the comparison website chooses not to disclose all the quotes, then the criteria used to select the products should be explained.
- Presentation of information – EIOPA considers it good practice to (1) present information on the main features and characteristics of products, insurance cover and limitations, as well as the length of the validity of the quote; (2) present information in a manner that is uniform and appropriate for the complexity of the products; (3) communicate in a clear and simply language, avoiding jargon and technical terms where appropriate; (4) provide the user with the final premium and details of all fees and charges, or if this is not possible, clearly state what additional charges and/or fees are to be paid; and (5) clearly disclose information on what is covered for each product offered.
- Frequency of updating information – EIOPA considers it good practice to publish accurate and up-to-date information, and to disclose to the user the date of the latest update before the search for products is initiated.