Insurance Europe recently published its comments on the EIOPA consultation on the proposal for guidelines on product oversight and governance arrangements. Insurance Europe urges EIOPA to consider whether guidelines are required in this area, in light of Insurance Distribution Directive delegated acts.  Notably, Insurance Europe (a) views the proposed timing involved as problematic (stating that it will provide a narrow window for insurers and distributors to make adjustments following publication of the finalised guidelines in Q2 2016) and (b) expresses concern as to the potential retroactive application of the proposed guidelines (stating that they should only apply to newly designed products).