Question ID: 2440
Regulation Reference: (EU) No 2016/97 - Insurance Distribution Directive
Topic: Definitions (Art. 2 IDD)
Article: 1 and 2
Status: UnderReview
Date of submission: 24 May 2022
Question
Art. 2 of IDD does not define who a "customer" is in the context of insurance distribution activities. Should we consider policyholders only? Or also insured persons?
Background of the question
The question is related to specific instances where a distributor provides insurance coverage to its clients, by recurring to "collective insurance policies" where contractually the distributor is the policyholder while its clients are insured persons only. For example, insurance bundled with a credit card or a loan or a cash accounts, where a bank is the policyholder and its clients are insured persons only. Would the insured persons be considered as "customers" in these scenarios and therefore would these activities fall in scope of the "insurance distribution activity" as defined in IDD?