Revised answer published on 19 December 2025:

In order to guarantee that the same level of protection applies regardless of the channel through which customers buy an insurance product, either directly from an insurance undertaking or indirectly from an intermediary, the scope of the IDD needs to cover not only insurance undertakings or intermediaries, but also other market participants who sell insurance products on an ancillary basis, such as travel agents and car rental companies, unless they meet the conditions for exemption (recital 8 of the IDD).

The IDD does not provide an exhaustive list of ancillary insurance intermediaries, rather gives an exemplificative selection of natural or legal persons who can provide insurance distribution on an ancillary basis. IDD excludes specifically only credit institutions and investment firms from the possibility of conducting distribution activities on an ancillary basis. Recital 15 of the IDD gives examples of a good or service in relation to which insurance can be complementary, such as train journey, gym subscription or a seasonal theatre pass, other risks linked to travel such as travel cancellation or loss of baggage. Recital 15 also notes that the IDD should not apply to persons practising insurance distribution as an ancillary activity where the

premium does not exceed a certain amount and the risks covered are limited. 

Freight forwarders, who arrange the movement of goods and may offer insurance covering either:

• damage, loss or theft of the goods during transport; or
• their own contractual liability,

may fall within the definition of an ancillary insurance intermediary insofar as all the requirements of Article 2(1), point (4)(a)–(c) are fulfilled.

It should be noted that the IDD does not apply to ancillary insurance intermediaries carrying out insurance distribution activities where all the conditions under Article 1(3) of the IDD are met. This exemption is intended for low-risk, low-premium, limited-coverage insurance that is complementary to a good or short-term service, as illustrated in Recital 15.

With respect to freight forwarding:

• The insurance associated with freight forwarding typically covers high-value goods or significant liability exposures, which usually exceed the premium thresholds in Article 1(3)(b)–(c);
• The risks covered (loss or damage of commercial cargo, or liability for failure to perform the carriage contract) generally cannot be considered limited risks within the meaning of Recital 15;
• Article 1(3)(a)(i) relates to the risk of breakdown, loss of, or damage to, the good supplied by the same provider. Freight forwarders do not supply the transported goods, so this condition is typically not met;
• Article 1(3)(a)(ii), concerning travel-related risks such as baggage, is aimed at travel services provided to natural persons. Freight forwarding, which concerns commercial cargo and contractual logistics, does not fall within the intended scope of this provision.

Therefore, freight forwarders will usually not meet all the conditions of Article 1(3) and are therefore subject to the IDD when distributing insurance, even when acting as ancillary insurance intermediaries.

Answer published until 19 December 2025:

In order to guarantee that the same level of protection applies regardless of the channel through which customers buy an insurance product, either directly from an insurance undertaking or indirectly from an intermediary, the scope of the IDD needs to cover not only insurance undertakings or intermediaries, but also other market participants who sell insurance products on an ancillary basis, such as travel agents and car rental companies, unless they meet the conditions for exemption (recital 8 of the IDD).
The IDD does not provide an exhaustive list of ancillary insurance intermediaries, rather gives an exemplificative selection of natural or legal persons who can provide insurance distribution on an ancillary basis. IDD excludes specifically only credit institutions and investment firms from the possibility of conducting distribution activities on an ancillary basis. Recital 15 of the IDD gives examples of a good or service in relation to which insurance can be complementary, such as train journey, gym subscription or a seasonal theatre pass, other risks linked to travel such as travel cancellation or loss of baggage.
Consequently, a freight forwarder can be considered an ancillary insurance intermediary provided that all the conditions mentioned in Article 2(1) point 4 of the IDD are met. It should be noted that the IDD does not apply to ancillary insurance intermediaries carrying out insurance distribution activities where all the conditions under Article 1(3) of the IDD are met.