Insurance Europe was commenting on the European Commission's creation of a "retail package", the proposals for revisions to the Insurance Mediation Directive and for the regulation of packaged retail investment products in the European Union.
Insurance Europe believes that similar principles should apply to the regulation of all distribution channels for selling insurance products.
However, these principles need to be tailored to and proportionate to the channel concerned.
The possibilities for conflicts of interest and the need for transparency in remuneration, for example, vary depending on the channel through which products are sold, the federation said.
"The focus of the regulation must be on ensuring comparable levels of protection for all consumers. To achieve this outcome, the regulation must be flexible enough to be adapted to the channel concerned", said Michaela Koller, director general of Insurance Europe.
In particular, to achieve the objective of improving consumer information on PRIPs, it is crucial that the Commission's proposed introduction of a key information document does not result in the duplication of existing disclosures or in the provision of irrelevant information, which would confuse consumers and lead to legal uncertainty, the federation said.
Moreover, requiring employees of insurance undertakings to disclose the variable element of their remuneration when selling an insurance product, for example, would not help a customer in their choice of product.
By adding to the current abundance of pre-contractual information in the revised Insurance Mediation Directive, such a requirement would confuse consumers with irrelevant information rather than encouraging them to focus on key factors, such as the insurance cover provided.
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