Die IDD setzt Maßstäbe für alle Versicherungsvermittler

IDD sets high standards for the sale of insurance products, regardless of whether they are distributed online or offline. Even simple insurance products, such as travel cancellation insurances, extended warranties for electrical appliances or mobile phone insurances, are affected. Travel agents or electronic retailers who also offer e.g. cancellation insurances or transport insurances (whether online or offline), are covered by the Directive as ancillary insurance intermediaries.

This article discusses in a little more depth the identification of the demands and needs as well as the advice and what a valid waiver of advice is supposed to look like.

Determination of demands & needs (also in online sales) by insurance intermediaries

Specification of the demands and needs pursuant to Article 20 of the IDD (§ 3 VO – Standesregeln)

Basically, the insurance intermediary must always clarify the customer’s demands and need. This provided, the insurance intermediary must ensure that the insurance contract offered suits to the previously determined demands and needs.

Pursuant to Article 20 of the IDD (§ 3 VO – Standesregeln), the specification of the demands and needs must be in accordance with the complexity of the insurance product(s) concerned. The simpler the relevant insurance product or the smaller the product range offered, the easier it will be to specify the demands and needs.

In order to enable the customer to take a well-informed decision, the relevant information on the insurance product concerned must be provided to him prior to the conclusion of the contract. This information is supposed to be provided at any appropriate position right at the beginning of the sales process and is basically a summary of the Insurance Product Information Document (“IPID”).


On the basis of the previously determined demand and needs, the insurance intermediary shall make a recommendation in accordance with professional criteria, regarding which insurance contract would be adequate to meet the customer”s demands and needs. Again, the complexity of the product concerned as well as the product range offered must be taken into account.

Specification of demands and needs and provision of advice in the Online – customer journey

In the online sales process of a charter cancellation insurance, the determination of the demands and needs and the provision of advice might be presented as follows:

Example of determination of the demands and needs and the provision of advice on boat-bsurance.com

Waiver of advice (§ 3 VO – Standesregeln)

In case an insurance product is distributed by an agent, the customer may waive receiving advice from the agent, if:

  • the insurance distribution activity is carried out at the initiative of the customer
  • the customer has been clearly informed, that no advice will be provided
  • the customer declares the waiver of advice in a separate document
  • the customer is not induced to the waiver of advice by the agent

It should be noted that also when insurance distribution activities are carried out through an ancillary insurance intermediary who is exempted from the application of the relevant provisions the insurance undertaking or insurance intermediary shall ensure that appropriate and proportionate arrangements are put in place to consider the demands and needs of the customer before the proposal of the contract.

For example, if an (Online-) travel agent intends to sell a travel cancellation insurance in addition to the travel bookings, the above stated obligations may also apply to a limited extent.

bsurance, as an online insurance expert, may provide you with all necessary support you need for the quick implementation of your customer journey.

Find the full IDD-series here on our blog!