The publication by the European Insurance and Occupational Pensions Authority (EIOPA) of updated IDD sanctions data (2018–2024), Data on sanctions imposed on insurance distributors – European Insurance and Occupational Pensions Authority together with its Third Report on the application of the Insurance Distribution Directive (30 March 2026), offers a useful moment to step back.
More than six years after the IDD entered into force, these two publications allow a combined reading of how the framework works in practice: where supervisors intervene through enforcement, how supervisory priorities have evolved, and what this tells us about market behaviour.
Taken together, EIOPA’s figures do not point to a single, uniform supervisory model across the EEA. National competent authorities continue to rely on different enforcement tools, sanctioning thresholds and procedural approaches. These differences reflect national legal and institutional choices, not necessarily diverging regulatory standards or objectives.
At the same time, one clear and consistent trend emerges across Member States: supervisory attention has progressively shifted away from purely formal or technical deficiencies towards behavioural outcomes. Supervisors increasingly focus on how insurance distribution operates in practice; whether advice is appropriate, whether customers’ interests are effectively protected, and whether organisational arrangements genuinely support compliant behaviour.
For Belgium, EIOPA’s harmonised data reflects a supervisory approach that places strong emphasis on early corrective intervention. Structural or organisational shortcomings are first addressed through measures aimed at restoring compliance, with more definitive sanctions used where necessary. As EIOPA explicitly notes, such differences in supervisory reaction should not be interpreted as differences in compliance culture, but as expressions of distinct supervisory models operating under a shared European framework.
This note summarises the main quantitative trends and structural developments identified by EIOPA. The full reports are available in annex.
1. Sanctions under the IDD: evolution over time (2018–2024)
Since the IDD entered into application:
- reported sanctions increased after the first year,
- peaked around 2021, and
- have since stabilised at a lower level.
EIOPA links the 2021 peak to the completion of first full supervisory cycles, increasing familiarity with the IDD, and the normalisation of sanctioning procedures. Importantly, EIOPA stresses that annual fluctuations mainly reflect supervisory practices, rather than changes in underlying market behaviour.
For 2024, national authorities reported 1,656 IDD-related sanctions across the EEA. After several full supervisory cycles, EIOPA considers sanctions data to reflect ongoing, mature application of the IDD rather than a transitional phase.
2. Geographic scope and reporting
In 2024:
- 24 EEA countries reported IDD sanctions,
- six countries did not report sanctions.
EIOPA underlines that the absence of reported sanctions does not mean the absence of supervision. It often reflects the use of informal or corrective measures that fall outside the scope of reportable sanctions under the harmonised methodology.
3. Types of sanctions: how supervisors intervene
Across the EEA in 2024, the most frequently used sanction type was:
- withdrawal of registration, accounting for 51% of all sanctions.
Other measures include cease-and-desist orders, administrative fines and other supervisory actions. The mix varies significantlyn. De samenstelling van deze instrumenten verschilt sterk per lidstaat, afhankelijk van het nationale kader en de handhavingstraditie.
Belgium in context
Belgium accounts for 275 sanctions out of 1,656 reported across the EEA (≈16.6%). The Belgian profile is marked by a strong reliance on:
- orders to cease and desist (≈81.5%),
- complemented by withdrawals of registration (≈16.7%),
- with administrative fines used selectively (≈1.8%).
Compared with the EEA as a whole, where withdrawals dominate, Belgium relies more heavily on corrective interventions. As EIOPA notes, this reflects supervisory choice, not differing regulatory ambition.
4. Types of breaches: what sanctions relate to
Organisational and professional requirements
Over the full reporting period, a substantial share of sanctions relates to Article 10 IDD requirements, notably:
- registration conditions,
- professional indemnity insurance,
- knowledge and competence rules.
These issues are not confined to the early years of the IDD and remain a recurring focus of supervision.
Conduct of business rules
For 2024, EIOPA provides more granular insight into conduct-related breaches. Most sanctions in this category concern failures to:
- act honestly, fairly and professionally,
- act in the best interests of customers.
Compared with the early years of IDD application, this confirms a growing focus on behavioural outcomes, rather than purely formal compliance.
Belgium: breach profile
Belgium shows a distinct pattern: around 93% of reported breaches relate to conduct of business requirements, while organisational issues play a much smaller role. This contrasts with the EEA aggregate, where organisational breaches dominate.
This suggests that in Belgium, supervisory intervention is more often triggered by how rules are applied in practice, rather than by structural deficiencies — again reflecting supervisory focus rather than compliance levels.
5. Fines – numbers versus amounts
In 2024:
- fines were imposed in 11 EEA countries,
- total fine amounts per country ranged from EUR 10,000 to EUR 516,000,
- the total EEA amount reached EUR 1.58 million.
Belgium reported five fines for a total of approximately EUR 407,500, concentrated on a limited number of cases linked to core professional and organisational obligations. Fines appear to function as a targeted supervisory tool, rather than a routine enforcement instrument.
EIOPA stresses that monetary values should always be read alongside other supervisory measures, not in isolation.
6. Broader supervisory context
EIOPA’s IDD Application Report places enforcement data in a wider context:
- the number of registered intermediaries continues to decline,
- cross-border distribution is increasing (+12% EU passporting between 2020 and 2024),
- supervisory attention increasingly targets advice quality, sales practices and outcomes rather than procedural box‑ticking.
Studies such as EU-wide mystery shopping confirm that more complex processes do not necessarily lead to better consumer outcomes.
EIOPA also flags emerging supervisory attention to digitalisation, AI-based distribution tools, sustainability disclosures and overlapping regulatory frameworks; areas where guidance and supervisory convergence are seen as more appropriate than immediate legislative change.
Concluding perspective
EIOPA’s data shows a clear shift:
- from initial implementation towards mature supervision,
- with continued focus on organisational and conduct of business rules,
- widespread use of corrective measures,
- and increasing attention to real-life outcomes for customers.
Sanctions alone do not define supervisory effectiveness and must always be read alongside broader market and supervisory analysis.
In this context, professional associations play a key role. Through ongoing dialogue with EIOPA and EU institutions – notably via BIPAR at European level – we help translate supervisory expectations into practical, proportionate and workable arrangements for intermediaries.
Executive box: key figures at a glance
IDD supervision: EIOPA highlights
| EEA | Belgium | |
| Period covered | 2018–2024 | 2018–2024 |
| Sanctions (2024) | 1,656 | 275 |
| Most used sanction | Withdrawal of registration (51%) | Cease and desist orders (≈ 82%) |
| Main breach categories | Organisational & professional requirements Conduct of business principles | Conduct of business principles |
| Fines (2024) | EUR 1.58 miljoen | ≈ EUR 407,500 |
Market trend: fewer intermediaries, more passporting
Supervisory trend: from formal compliance to outcome‑based supervision
Note: EIOPA data is based on a harmonised EU reporting methodology and may differ from national supervisors’ figures (e.g. FSMA), due to methodological choices rather than inconsistencies.
