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Insurance Distribution Directive



The Insurance Distribution Directive (IDD) should replace the Insurance Mediation Directive (IMD) by 1 October 2018. 

The IDD is a new EU wide directive aimed at ensuring minimum harmonisation of insurance distribution regulation across the EU, creating a ‘level playing field’ for insurance intermediaries and insurance distribution, regardless of the channel customers use to purchase their products. The aim is to ensure consistent prudential standards for intermediaries as well as significantly raising conduct standards, improving consumer protection and effective competition. 

The IDD applies to insurers, insurance intermediaries, price comparison websites/aggregators and ancillary insurance intermediaries. The conduct requirements applying to distributors (which includes insurers) vary according to the nature of the business, customers (including commercial clients) and distribution channel used.


Key areas covered by the regulation include: 

  • Professional, organisational and prudential requirements: covers professional indemnity cover, and training and competence requirements. 
  • Conduct of business general principles including acting in customers’ best interest. 
  • Product oversight and governance requirements (POG). 
  • Remuneration disclosure requirements. 
  • Conflicts of interest disclosure. 
  • Pre-contract disclosures. 
  • Customer demands and needs requirements. 
  • Complaints handling and out of court redress.

With IDD being minimum harmonisation, each EU Member State is able to top up the regulation, and as a result it will have its own version of the IDD. 

What next?

At this stage, firms should be at an advanced stage of considering their readiness for the IDD. 

The next six months will be crucial in terms of testing and remediating any IDD implementation measures. This will ensure that systems and processes are as robust as possible on the go-live date.

How can PwC help?

PwC is able to offer a multi-disciplinary team that draws on subject matter experts with experience of advising insurance clients. We are able to assist with many aspects pertaining to IDD implementation including the provision of an IDD Health Check. A health check is a cost effective way of obtaining assurance that your organisation is ready to comply with the salient aspects of the IDD as from the first day of it’s implementation.

Some benefits and practical solutions

  • Helping to identify key areas of focus in terms of IDD compliance.
  • Assessing the extent of risk attributed to current processes and procedures.
  • Identifying compliance gaps and an opportunity to rectify any areas of non-compliance immediately.
  • Recommendations for setting up control frameworks as necessary.

Contact us

Romina Soler

Romina Soler

Assurance Partner, PwC Malta

Tel: +356 2564 7293

Mirko Rapa

Mirko Rapa

Tax Partner, PwC Malta

Tel: +356 2564 6896

Christopher  Cardona

Christopher Cardona

Assurance Partner, PwC Malta

Tel: +356 2564 2610

Mark Abela

Mark Abela

Senior Manager, Tax, PwC Malta

Tel: +356 2564 6954

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