Insurance Distribution Directive Update

Article Publish Date: Wednesday 6 September 2017

The changes are wide-ranging, affecting sales journeys, product literature and product governance through to training and remuneration disclosure.



What’s changing?

  • The complexity of modifications to the sales journey are particularly challenging with modifications to obtaining Demands and Needs, consent for online documents and Insurance Product Information Document (IPIDs) to replace the policy summary.
  • In line with the requirements we can confirm that from February 2018 IPIDs will be provided for all Personal Lines products.
  • For Commercial Lines customers we will ensure that all of the information required in a IPID is provided but not necessarily in the same format. The FCA guidance permits this approach.
  • Like you, we recognise that the timescales for delivery are further compressed by the timescales imposed from Europe and uncertainty over deliverables. This is compounded by ongoing FCA consultation and final rules not being known until January 2018, just one month prior to implementation. 

What are we doing?

  • Our implementation programme is progressing on the basis of the draft regulations, which may differ from the final requirements. We acknowledge that we may need to adapt what we have implemented once the full rules are announced.
  • We’re confident that the actions we’re taking will make sure there’s no customer detriment resulting from the IDD changes after February 2018   

What do you need to be doing?

  • We hope that you’re preparing for the changes as timescales are challenging.
  • We’ll continue to provide further updates, but in the meantime, if you require further information then visit FCA, BIBA or EIOPA websites.


If you have any questions about this, please get in touch with Wilf Gibbons on or 07786 855 591.

We’ll continue to provide you with regular updates.

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