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Personal Finance Society
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FCA consultation on the transposition of the European IDD

Consultation Response

We welcome the transposition of the Insurance Distribution Directive (IDD), and look forward to working with the FCA and Treasury in its implementation. 

We have been actively involved in discussions leading to the current professionalism provisions within the Insurance Distribution Directive (IDD) since before the European Commission first consulted on a possible proposal for a re-cast Insurance Mediation Directive in 2011.

  • We were actively involved in the discussions at the EU level that resulted in the Directive’s provisions on professional standards. We participated in consultations on good supervisory practices led by the European Insurance and Occupational Pensions Authority (EIOPA) that formed the backbone of the IDD provisions.
  • While we support the professional requirements set out, we have several points to note: First, the IDD is being introduced at the same time as the Senior Managers & Certification Regime which identifies additional requirements for staff roles carrying a higher risk.
  • Second, the IDD 15 hours of CPD should be seen as a minimum standard for staff filling positions which have lower risk of harm to the public. Staff that hold qualifications and/or positions that carry higher risk such as Senior Management or Significant Harm Functions should be required to meet a stronger CPD regime. Finally,
  • In terms of helping compliance, we encourage an approach which encourages firms to think more carefully about linking CPD to annual learning needs.

 Consultation response