While the Insurance Distribution Directive (IDD) has been in force in each EU member state since 2018 at the latest, its implementation has only become the focus of supervisory authorities in the last two years. Of particular importance are the requirements for the product approval process according to Article 25 IDD in connection with the Delegated Regulation on product oversight and governance requirements (POG). Specifically, this relates to requirements for the development and distribution of new products and significant adaptations of existing insurance products. The requirements serve to effectively protect consumers and are part of the business organization of insurance undertakings. Depending on the nature of the insurance product and the risk of consumer detriment related to it, the product approval process essentially includes
- defining a target market for the insurance product, determining and assessing the relevant risks for this target market,
- testing the insurance product, including scenario analyses, to ensure that the product meets over its whole lifetime the identified needs, objectives and characteristics of the defined target market,
- determining a distribution strategy corresponding to the target market and the information to be provided to distributors,
- ensuring that the insurance product is distributed to the defined target market, and
- monitoring and regularly reviewing the insurance product.
The product approval process under IDD therefore goes well beyond the process how an insurance product was designed and developed by insurance undertakings before the application of the IDD.