The answer to this question is provided by the European Commission.

According to Article 2(1)(10) IDD, ‘home Member State’ of an insurance intermediary means, in the case of natural persons, the Member State in which his or her residence is situated and, in the case of legal persons, the Member State in which the registered office or the head office is situated. Article 3(1) and (4) IDD provides that insurance, reinsurance and ancillary insurance intermediaries shall be registered with the competent authority in their home Member State if they fulfil all the relevant requirements laid down in Article 10 IDD. The register indicates also the Member States in which the intermediary conducts business under the freedom to provide services or the freedom of establishment, as stated in Article 3(1)(9) IDD. Therefore, in accordance with the principle of single registration, the decision to register an intermediary, valid for the whole of the EEA, is the sole responsibility of the competent authority of the home Member State. There is no requirement for a separate or additional registration with the competent authority of the host Member State, neither for the intermediary nor for any staff members.

With regard to professional requirements, Article 10(1) IDD states clearly that “home Member States shall ensure that insurance and reinsurance distributors […] possess appropriate knowledge and ability in order to complete their tasks and perform their duties adequately”. Article 10(2) IDD provides further that “home Member States shall have in place and publish mechanisms to control effectively and assess the knowledge and competence of insurance and reinsurance intermediaries, employees of insurance and reinsurance undertakings and employees of insurance and reinsurance intermediaries”.

It follows from these provisions that professional and organisational requirements in accordance with Article 10 IDD are under the sole responsibility of the home Member State. Recital 22 of the IDD further confirms that ’responsibility for compliance with obligations affecting the business as a whole — such as the rules on professional requirements — should remain with the competent authority of the home Member State’. Consequently, host Member States do not have the possibility to impose professional requirements, such as initial and continuing professional training, to local staff of insurance and reinsurance intermediaries from other Member States operating under the freedom to provide services or the freedom of establishment. The responsibility of the host Member State is limited to ensuring that the services provided by the branches within its territory comply with the obligations laid down in Chapters V and VI of the IDD (see Article 7(2) IDD).

Disclaimer provided by the European Commission:

The answers clarify provisions already contained in the applicable legislation. They do not extend in any way the rights and obligations deriving from such legislation nor do they introduce any additional requirements for the concerned operators and competent authorities. The answers are merely intended to assist natural or legal persons, including competent authorities and Union institutions and bodies, in clarifying the application or implementation of the relevant legal provisions. Only the Court of Justice of the European Union is competent to authoritatively interpret Union law. The views expressed in the internal Commission Decision cannot prejudge the position that the European Commission might take before the Union and national courts.