Insurance EuropeInsurance Europe
Position Paper
Response to ESA Joint Committee consultation on guidelines for cross-selling practices

Insurance Europe response to a consultation by the Joint Committee of the European Supervisory Authorities on guidelines for cross-selling practices.

Insurance Europe stressed among other things the importance of ensuring a coherent approach and avoiding going beyond the scope and requirements of the relevant primary legislation. It also highlighted that the guidelines should not address issues and requirements that are not specific to cross-selling practices, particularly when such issues apply to the sale of all insurance products, eg advice, disclosures, training and remuneration.

Provisions on cross-selling are still being discussed as part of the ongoing review of the Insurance Mediation Directive (IMD 2), and may be subject to further changes in the course of trialogue negotiations. Insurance Europe therefore welcomed the Joint Committee’s acknowledgement of this fact and highlighted the importance of ensuring that the proposed guidelines are fully aligned with the final provisions of IMD 2.

Published 23 March 2015
Arthur Hilliard
Arthur Hilliard
Policy advisor