Several EU regulatory initiatives relevant to insurance distribution have progressed over the summer. While the Retail Investment Strategy (RIS) is moving towards formal adoption and detailed implementation, negotiations on SFDR (Sustainable Finance Disclosure Regulation), PEPP (Pan-European Personal Pension Product) and IORP (Institutions for Occupational Retirement Provision) have advanced through new Council or European Parliament positions. At the same time, AMLA (Authority for Anti-Money Laundering and Countering the Financing of Terrorism) is translating the new EU anti-money laundering framework into more detailed operational requirements.<\/p>\n\n\n\n
Although these files are at different stages, attention is increasingly turning to their practical impact on insurance intermediaries, from advice, product governance and disclosure requirements to AML monitoring and reporting. Proportionality, avoiding unnecessary duplication and ensuring that requirements reflect the actual role of intermediaries remain important themes across the different files.<\/p>\n\n\n\n
Following our June update, the Retail Investment Strategy (RIS) remains on track for formal adoption. With the political negotiations effectively concluded, attention is increasingly shifting to how the new framework will be implemented in practice.<\/p>\n\n\n\n
The RIS package amends several pieces of EU financial-services legislation, including the Insurance Distribution Directive (IDD). Many of the most significant new conduct-of-business requirements for insurance distributors concern insurance-based investment products (IBIPs), although certain IDD amendments have a broader scope.<\/p>\n\n\n\n
The next important phase is Level 2, where the principles agreed in the legislation will be translated into more detailed rules. The Commission has asked EIOPA to develop technical advice for the IDD, covering areas including value for money and product governance, inducements, suitability and appropriateness, marketing communications and simplification of the customer journey. In parallel, ESMA is undertaking similar work under MiFID II.<\/p>\n\n\n\n
For brokers, this is where much of the practical impact of RIS will be determined. Key questions include what information manufacturers and distributors will need to exchange, how value for money will be assessed, how remuneration and inducement rules will operate, and what changes may be required to existing advice, client information and documentation processes.<\/p>\n\n\n\n
An important test will be whether the Level 2 work delivers on the stated objective of simplifying the retail investor journey and reducing unnecessary complexity, rather than creating additional layers of compliance. Clear and proportionate allocation of responsibilities between manufacturers and distributors will be particularly important.<\/p>\n\n\n\n
Becobra will continue to follow the Level 2 work closely together with BIPAR and contribute where the developing rules materially affect insurance distribution.<\/p>\n\n\n\n
The implementation of the new European anti-money laundering framework is moving forward. Over the past months, AMLA has already consulted on several elements of the new Single Rulebook, including customer due diligence, the identification of business relationships and occasional transactions, group-wide AML requirements and business-wide risk assessments.<\/p>\n\n\n\n
Attention is now shifting to further aspects of the day-to-day application of the new rules. Two current initiatives are relevant for insurance intermediaries.<\/p>\n\n\n\n
AMLA is finalising Guidelines on how obliged entities should keep customer information up to date and monitor transactions and activities throughout a business relationship.<\/p>\n\n\n\n
Insurance intermediaries generally have a very different risk and transaction profile from banks or payment institutions. Many brokers do not collect premiums or execute or control financial transactions, while the number of suspicious activity reports originating from insurance intermediaries has historically been very low. The advocacy therefor strongly focuses on proportionality.<\/p>\n\n\n\n
The objective is not to weaken AML controls, but to ensure that monitoring requirements are effective and reflect the activities, information and risks actually present in the intermediary business model. AMLA’s own draft Guidelines recognise that pre-transaction or real-time monitoring may not be applicable where an obliged entity does not execute or control transactions.<\/p>\n\n\n\n
The consultation closes on 3 September 2026. AMLA intends to issue the final Guidelines in Q4 2026.<\/p>\n\n\n\n
In parallel, AMLA is consulting on harmonised formats for reporting suspicions and providing transaction records to Financial Intelligence Units (FIUs). The objective is to replace the widely differing national reporting formats with a more consistent European approach.<\/p>\n\n\n\n
The proposed framework contains a detailed set of potential data points, although AMLA stresses that reporting entities would only have to complete those relevant to their activity and the particular suspicion being reported.<\/p>\n\n\n\n
Here again, proportionality and the intermediary business model will be important. The question is whether the information requested is relevant and realistically available to an insurance intermediary, and whether the reporting process is proportionate to the actual risk and reporting exposure of the sector.<\/p>\n\n\n\n
AMLA will hold a public hearing on the proposed reporting standards on 9 September 2026.<\/p>\n\n\n\n
Becobra will continue to contribute to the BIPAR work, with particular attention to ensuring that the new AML framework remains effective, risk-based and proportionate to the actual role of insurance intermediaries.<\/p>\n\n\n\n
Since our previous update on the review of the Sustainable Finance Disclosure Regulation (SFDR), the file has taken another step forward.<\/p>\n\n\n\n
The Council has now agreed its negotiating position on the proposed reform. This gives the Council a mandate to enter into negotiations with the European Parliament once Parliament has finalised its own position.<\/p>\n\n\n\n
The review seeks to address concerns that the current SFDR framework has become overly complex and difficult to apply in practice. While originally conceived as a transparency regime, SFDR has increasingly operated as a de facto product-labelling system. The reform therefore aims to simplify the framework, reduce administrative burdens and make sustainability-related financial products easier for investors to understand and compare.<\/p>\n\n\n\n
For insurance intermediaries, the Council position confirms an important direction already highlighted in our previous update: financial advisers would be removed from the direct scope of SFDR. The rationale is that advisers do not manufacture or manage sustainability-related financial products, but rather help clients identify products that correspond to their preferences.<\/p>\n\n\n\n
This would significantly reduce the direct SFDR compliance and reporting burden for intermediaries. The reform will nevertheless remain relevant to the distribution and advisory process. The new product categories are intended to help distributors identify products that match their clients’ sustainability preferences and are expected to be reflected in the relevant distribution rules.<\/p>\n\n\n\n
For brokers, the practical impact will therefore increasingly shift from direct SFDR compliance towards the advisory process: understanding the new product categories and the information provided by manufacturers, integrating these into the applicable sustainability-preference and target-market assessments, and translating that information into meaningful advice for clients.<\/p>\n\n\n\n
The Council position is not the final legislation. The next stage will be negotiations with the European Parliament, during which differences between the respective positions will need to be resolved before a final text can be adopted.<\/p>\n\n\n\n
Becobra will continue to follow the negotiations, together with BIPAR, with particular attention to the practical interaction between the revised SFDR framework and insurance distribution requirements.<\/p>\n\n\n\n
The review of the Pan-European Personal Pension Product (PEPP) is moving forward. PEPP is a voluntary personal pension product designed to allow individuals to save for retirement across the EU, with the possibility to remain in the same product when moving between Member States.<\/p>\n\n\n\n
Since our June update, the European Parliament\u2019s ECON rapporteur has published her draft report on the reform.<\/p>\n\n\n\n
For intermediaries, one of the main points concerns the role of advice. While the Commission had proposed reducing the mandatory advice requirements for the Basic PEPP, the rapporteur would retain advice as an important part of the sales process, while allowing this to be provided digitally by default.<\/p>\n\n\n\n
The draft report also seeks to avoid adding unnecessary new layers of product governance and value-for-money requirements specifically for PEPP, where broader distribution rules already apply.<\/p>\n\n\n\n
The rapporteur\u2019s draft is not yet the Parliament\u2019s final position and may still change during the coming discussions. Becobra will continue to follow the file together with BIPAR, in particular where the reform affects advice and distribution of retirement products.<\/p>\n\n\n\n
Since our June update, the review of the Institutions for Occupational Retirement Provision (IORP) framework has taken another step forward. IORPs are institutions that manage occupational pension schemes, typically organised by employers or sectors as part of the second pension pillar.<\/p>\n\n\n\n
On 24 June, the Council agreed its negotiating position on the proposed reform. The review continues to focus on improving the governance, transparency and effectiveness of occupational pension provision across the EU.<\/p>\n\n\n\n
A strong focus remains on better information for pension savers. The Council supports clearer and more comparable Pension Benefit Statements, including information on costs, investment performance and investment options. It also proposes more detailed information around the retirement and pay-out phase, helping members better understand the choices available to them.<\/p>\n\n\n\n
The review is also relevant for insurance undertakings and intermediaries that distribute occupational pension products. The Council position provides that they should ensure an equivalent level of information and protection, while explicitly seeking to avoid duplication where the required information has already been provided under existing EU rules such as the IDD.<\/p>\n\n\n\n
The Council position is not the final legislation. Negotiations with the European Parliament will determine the final shape of the framework. Becobra will continue to follow the file together with BIPAR, in particular where the reform affects information requirements and the distribution of occupational pension products.<\/p>\n","protected":false},"excerpt":{"rendered":"
Several EU regulatory initiatives relevant to insurance distribution have progressed over the summer. While the Retail Investment Strategy (RIS) is moving towards formal adoption and detailed implementation, negotiations on SFDR (Sustainable Finance Disclosure Regulation), PEPP (Pan-European Personal Pension Product) and IORP (Institutions for Occupational Retirement Provision) have advanced through new Council or European Parliament positions. […]<\/p>\n","protected":false},"author":3,"featured_media":12175,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[42,44,45,46,50],"tags":[83,91],"rol":[81],"class_list":["post-12181","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-european-dossiers","category-legal-affairs-and-compliance","category-life-insurance","category-non-life-insurance","category-systems-and-operations","tag-private","tag-slotje","rol-standaard-lid"],"acf":[],"_links":{"self":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/12181","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/comments?post=12181"}],"version-history":[{"count":5,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/12181\/revisions"}],"predecessor-version":[{"id":12192,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/posts\/12181\/revisions\/12192"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/media\/12175"}],"wp:attachment":[{"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/media?parent=12181"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/categories?post=12181"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/tags?post=12181"},{"taxonomy":"rol","embeddable":true,"href":"https:\/\/becobra.be\/en\/wp-json\/wp\/v2\/rol?post=12181"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}