Data on sanctions imposed on insurance distributors

Total number of sanctions over the years

Since the introduction of new rules for the distribution of insurance that were brought by the IDD in 2018, the number of sanctions peaked in 2021 (*), with 1,656 sanctions imposed in 2024.

Types of sanctions across the years

The most commonly used sanction has been the withdrawal of the registration (i.e. the license) of the company. In 2024, withdrawals of registration represented 51% of all sanctions imposed by national authorities.

Number and types of sanctions per Member State in 2024

In 2024, IDD sanctions were imposed in 24 Member States, while in the remaining 6 Member States (Iceland, Luxembourg, Lithuania, Slovakia, Spain and Sweden) no IDD sanctions were imposed. 

Breaches per Chapter of IDD for each Member State in 2024

The graph below shows the split between sanctions based on breaches of the rules in different chapters of the IDD across Member States in 2024. 

Conduct issues resulting in sanctions in 2024

For 2024, looking more specifically at sanctions for breaches of the information and conduct of business rules and additional requirements for insurance-based investment products (Chapters V and VI of IDD), the majority of these types of sanctions concerned the general principles for appropriate conduct of business by insurance distributors, such as always acting honestly, fairly and professionally and in accordance with the best interests of their customers.

Total value of fines across the years

In 2024, Member States imposed administrative pecuniary sanctions (i.e. fines) totalling 1,576,967 EUR, the highest total since 2018. 

Total value of fines per Member State in 2024

Fines were imposed in 11 Member States in 2024 - Belgium, Cyprus, Czechia, Estonia, Germany, Greece, Hungary, Italy, Poland, Portugal and Romania. Across these 11 Member States the total value of IDD fines within that Member State ranged from 10,000 EUR to 516,000 EUR.

Conduct issues resulting in fines in 2024

The graph below shows that in 2024 the highest number of fines were imposed for breaches of the professional and organisational requirements, but the total value of fines was higher for breaches of the product oversight and governance requirements.

Highest individual fines in 2024

The graph below looks at the largest individual fines imposed on insurance distributors during 2024 and the reason for these fines. This sample of the largest fines represents over 80% of the total value of fines imposed across all Member States.

Notes

• * The total number of sanctions in 2021 was exceptionally high due to a very high number of sanctions being imposed in specific Member States during this year. Please refer to the previous annual reports for further explanation of the figures (e.g. paragraph 3.15 of the EIOPA 4^th Annual Report on Administrative Sanctions and other measures under the IDD (2022)).

Additional information

• The data on sanctions covers administrative sanctions and other measures imposed on insurance distributors under the Insurance Distribution Directive (IDD). Insurance distributors are companies or persons selling insurance, including insurance undertakings (i.e. companies), insurance intermediaries (such as insurance brokers and insurance agents) and ancillary insurance intermediaries.

• The IDD does not provide a fully harmonised sanctioning regime across the EU. The Directive sets out essential requirements that sanctions need to satisfy, but important aspects of the sanctioning regime, remain subject to national law, including the types of sanctions.

• Since the IDD provides a non-exhaustive minimum list of sanctions that can be imposed, there can be some scope for interpretation as to whether specific national measures fall within the scope of IDD sanctions. Nonetheless, sanctions can include:
  • A public statement indicating the company or person responsible and the nature of the breach
  • An order requiring the responsible company or person to cease the conduct and to desist from a repetition of that conduct;
  • The withdrawal of the registration (i.e. licence) of the insurance intermediary
  • A temporary ban on the exercise of management functions in insurance intermediaries or insurance undertakings imposed against any member of the management body of the insurance intermediary or insurance undertaking
  • An administrative pecuniary sanction (i.e. a fine)

  • Other types of administrative sanctions or measures under national law. These can include censures, warnings, reprimands, the suspension of an intermediary’s registration or different types of orders (i.e. different to orders to cease and desist). 

     

• The imposition of sanctions is just one element of the toolbox available to national authorities after carrying out supervisory activities. Sanctions are an essential tool to dissuade misconduct, but, given that they are generally targeted at individual companies or individuals, other informal measures can also be an efficient and effective means to address broader market failures. In addition, there are significant divergences in approaches across Member States, such that differences in the numbers of sanctions can be the result of procedural differences, for example certain types of IDD breaches may result in a sanction being imposed in one Member State, but a different supervisory measure being taken in another Member State.