Insurance Distribution Directive

The Insurance Distribution Directive is EU legislation which sets regulatory requirements for firms designing and selling insurance products.

The Insurance Distribution Directive (IDD) replaces the Insurance Mediation Directive (IMD). It aims to enhance consumer protection when buying insurance – including general insurance, life insurance and insurance-based investment products (IBIPs) – and to support competition between insurance distributors by creating a level playing field.

Like the IMD, the IDD covers the authorisation, passporting arrangements and regulatory requirements for insurance and reinsurance intermediaries. However, the application of the IDD is wider, covering organisational and conduct of business requirements for insurance and reinsurance undertakings. The IDD also introduces requirements in new areas, including product oversight and governance, and enhanced conduct rules for IBIPs.

How does it affect me?

If you are affected by the IDD, you will be required to undertake 15 hours of CPD on an annual basis covering Insurance. If you are a Retail Investment Adviser this 15 hours can form part of your 35 hour annual CPD requirement.

Requirements

CPD requirements should take into account the role and activity you undertake and type of distribution and nature of the products you sell.

Knowledge and Competence

CPD

The FCA rules do not specify a starting date for the 12 month period. Firms/individuals can use their accounting reference date if they wish. However, firms/individuals should ensure that measures are in place to comply with the IDD requirements from 1 October 2018. This may mean doing a pro-rata amount of CPD in the first period after implementation, or completing the full 15 hours in that time. We will accept a pro rata amount.

Firms/individuals may also, if they wish, take into account CPD undertaken during the same 12 month period at a new employee’s former workplace. However, they should ensure that reasonable measures are in place to verify the completion of the previous CPD.

CISI CPD Scheme

The CISI is currently developing its CPD Scheme to enable members and firms to monitor their CPD progress in meeting these requirements. Please do visit this page regularly for updates on this development and the launch of new CPD opportunities in this area.

Legislation

The IDD is a minimum harmonising directive, which can be accessed in the Official Journal of the European Union:

The IDD enables the European Commission to make secondary legislation. That legislation is comprised of delegated acts and implementing technical standards. These can be accessed on the European Commission website:

Guidelines

The IDD also empowers the European Insurance and Occupational Pensions Authority (EIOPA) to develop supporting guidelines. These can be accessed on the EIOPA website:

  • Guidelines: under the IDD on insurance-based investment products that incorporate a structure which makes it difficult for the customer to understand the risks involved
  • Questions and Answers: on the application of the IDD in respect of product governance and the regulatory requirements for insurance-based investment products.

Timeline

Member States, including the UK, must implement the Directive into national law by 1 July 2018 (this was delayed from the original transposition date of 23 February 2018). The requirements will apply to firms from 1 October 2018.

Key Publications

Consultation Papers Policy Statements Handbook Notice IDD Quarterly Consultation Papers:

Feedback to CP17/32 and CP17/39 was provided in the third policy statement, PS18/1.

The Treasury has also published a consultation paper and feedback statement, which can be accessed on the Treasury website: