EIOPA published today a Consultation Paper on draft Implementing Technical Standards (ITS) standardising the presentation format of the Insurance Product Information Document (IPID). The IPID will be provided to the customer prior to the conclusion of a non-life insurance contract in accordance with the provisions of the Insurance Distribution Directive (IDD).
The purpose of the IPID is to ensure that key information about non-life insurance products is presented to the customer in a standardised format they can use to understand the product offered, and compare between different products.
The key information to be included in the IPID is already determined by the IDD. The goal of this consultation is to collect public feedback about the presentation of the IPID, including on such features as its length, the use of icons and symbols, possible advantages of digital and paper formats, etc.
EIOPA’s proposals for the IPID are based on two phases of consumer testing that were conducted among more than 3000 consumers in a representative sample of Member States.
The consultation will end on 24 October 2016. The consultation paper and the template for comments, together with the consumer testing report can be viewed here
Overview of Questions for Consultation:
Q1. What barriers, if any, do you see to utilising a single standardised presentation format for all non-life insurance products? If you believe barriers to a standardised presentation format exist, please describe how they could be overcome.
Q2. (a) Do you agree that visual aids such as icons and symbols used to distinguish different information requirements in the IPID should be highly standardised at a European level? (b) Are there any circumstances in which it is necessary to allow for differences in any such icons between Member States? If so please explain the circumstances.
Q3. (a) In what circumstances do you consider that it will not be possible to include the information required under the IPID on two sides of an A4 page? (b) Do you foresee any difficulties with prescribing a font type and font size?
Q4. (a) What challenges do you think a manufacturer would face, and how would these be overcome, in adapting the IPID to be compatible with provision via digital media such as websites, tablets or smartphones, including with preserving the fundamental aspects of the standardised presentation format? (b) What benefits do you see for the manufacturer in making the IPID compatible with the provision via digital media?
Q5. What do you consider are the main cost drivers for the standardised presentation format (not including the efforts associated with the collection, identification and assimilation of the information itself) and at what point will they occur?
Q6. Do you agree with EIOPA's approach to focus primarily on consumers (i.e. retail customers) in developing the IPID?
Legal background: The purpose of Implementing Technical Standards (ITS) is to determine the conditions of application of EU legislative acts, such as EU Directives – in this case, the IDD. ITS should not imply strategic decisions or policy choices. EIOPA is exercising the power to draft the ITS according to its Founding Regulation (Regulation 1094/2010), in conjunction with a specific empowerment under Article 20(9) of the IDD. EIOPA is required to submit the draft ITS to the European Commission by 23 February 2017 for endorsement as a Commission Implementing Regulation, which will be available in all EU official languages and legally binding in all EU Member States. The date on which the Commission Implementing Regulation would enter into force has not yet been decided, but the IDD has to be transposed by Member States into national law by 23 February 2018.