Insurance EuropeInsurance Europe
Position Paper
Key messages on the European Commission proposal for IMD 2

Insurance Europe supports a high level of protection for all consumers purchasing insurance products, and the best way to ensure this is for the proposal for a revised Insurance Mediation Directive (IMD 2) to recognise the diversity of insurance distribution markets across the EU that results from consumers’ differing demands and needs.

IMD 2 should be flexible and proportionate enough to accommodate this diversity to avoid any negative effects on consumers and ensure appropriate policyholder protection. As such, the proposed rules must be thoroughly tested in all member states along with their impact on consumers before introducing new and previously untested concepts into IMD 2.

Moreover, in the interests of consistency of the EU acquis, the sale of all insurance products that fall under the Solvency II regime should not be regulated by any regulation other than IMD 2.

Published 4 October 2012
Arthur Hilliard
Arthur Hilliard
Senior policy advisor