Article 30, IDD places a requirement on the insurance intermediary or insurance undertaking, in the context of the suitability assessment to obtain the necessary information regarding the customer’s or potential customer’s knowledge and experience in the investment field relevant to the specific type of product or service, that person’s financial situation including that person’s ability to bear losses, and that person’s investment objectives, including that person’s risk tolerance.

In that respect, the use of profiling tools and other similar tools may suggest evidence of suitability, but only to a limited extent. It also depends on the evidence of how the tools are deployed and the results produced to assess the information provided by the customer.  

To the extent that such tools would form part of an automated or semi-automated system, Article 12 of Delegated Regulation 2017/2359 on Automated Advice would apply.