Manufacturers shall ensure that staff members involved in designing and manufacturing insurance products have the necessary skills, knowledge and expertise to properly understand the insurance products sold and the interests, objectives and characteristics of the customers belonging to the target market (Article 5 (4) Delegated Regulation 2017/2358). This includes understanding of the level of information available to the customers and the financial literacy of the customers. 

EIOPA considers that the manufacturer can demonstrate they have taken into account the level of information available to the customers and the financial literacy of the customers by, for instance, documenting the relevant choices they have made in the product approval process based on the aforementioned information. In particular, as stated by Article 9 of Delegated Regulation 2017/2358, all relevant actions taken by the manufacturer in relation to their product approval process shall be duly documented, kept for audit purposes and made available to the competent authorities upon request.