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Making sense of GI knowledge and ability at EU level

CII policy submission to EIOPA

This paper sets out some high-level views on the delegated acts provision in Art 8(8) of the European Commission’s proposal for a revised Insurance Mediation Directive (IMD2). It focuses on the three areas specified: (1) Knowledge and ability; (2) Appropriate criteria for determining levels of qualifications, experience and skills; and (3) Continuing professional development.

The revised Insurance Mediation Directive (IMD2) published in July 2012 calls for enhanced professionalism requirements that go beyond the provisions in the existing IMD. Whereas the existing Directive contains a high-level provision for intermediaries to possess the appropriate knowledge and ability, the new proposal goes into further detail on matters related to professionalism. Among the new requirements, Article 8(8) empowers the European Commission (EC) to adopt delegated acts that specify:

  • The notion of adequate knowledge and ability for insurance intermediaries;
  • Appropriate criteria for determining professional qualifications, experience and skills required; and
  • The steps that insurance intermediaries and undertakings might reasonably be expected to take to update their knowledge and ability through continuing professional development (CPD).

The European Insurance and Occupational Pensions Authority (EIOPA) expects the EC to request from them more detailed guidelines for implementing these provisions. As a first step to both this and the supervisory authority’s work to develop training standards for the industry, EIOPA published a report mapping industry training standards across member states.1 While it described the mandatory requirements set out by competent authorities in varying levels of detail, it represented an incomplete picture because it omitted additional requirements that have been imposed on practitioners by professional bodies.

To assist in EIOPA’s forthcoming work on the IMD2 delegated acts provisions, we have prepared this paper setting out some views on how these could be implemented. For each of the three areas (knowledge and ability; criteria for determining qualifications levels and experience; and steps for CPD), we have:

  • set out some detail, based on our own experience, on what could be involved;
  • provided illustrations and examples of the work that we have been doing in these areas; and
  • proposed possible high-level implementing measures to reflect actions by both competent authorities, professional bodies where relevant, and the industry itself.

 See our attached policy submission »