Insurance Europe: Insurers welcome repeal of DMD, but warn on unintended consequences of remaining provisions

26 October 2022

Insurance Europe strongly welcomes the repeal of the DMD but recommends transferring its remaining provisions to more recent sector-specific EU legislation, such as the Insurance Distribution Directive.

Insurance Europe has published a set of key messages regarding the repeal of the EU’s Directive on Distance Marketing of Consumer Financial Services (DMD).

It is also important for policymakers to:

• Ensure legal certainty and avoid duplication of requirements, such as disclosures, should the remaining provisions be transferred to the Consumer Rights Directive.
• Avoid unintended detrimental consequences resulting from the introduction of a new withdrawal button, as, for example, consumers may find themselves inadvertently uninsured.
• Remove the requirement for pre-contractual information at least one day before the time at which the consumer is bound by any distance contract. This is at odds with consumers’ expectations of speedy and easy purchasing processes in an increasing digital world, and their needs for immediate insurance coverage, for example when travelling or renting a car.
• Remove the requirement to always be able to obtain human intervention as it would not be compatible with digital developments. For example, chatbots are available 24/7 and requiring human intervention to also be available 24/7 would be extremely burdensome.
• Provide insurers with sufficient transposition time: for example, a minimum of six months from the end of the implementation period.

Insurance Europe

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