Insurance Europe says the EU must ensure that the proposals for change to the Insurance Mediation Directive (IMD2) must be flexible and proportionate. Its key messages are:

  • IMD2 should not extend to insurers or to non-mediation activities;
  • conflicts and remuneration policies should be designed with customer interests in mind and be risk-based;
  • consumers should have access to non-advised sales;
  • regulators must take care not to over-regulate or duplicate (particularly bearing in mind insurance Packaged Retail Investment Products (PRIPs); and
  • there must be a consistent approach to regulation across financial products in respect of cross-selling practices.

(Source: Insurance Europe Wants Proportionate and Flexible IMD2)