EIOPA has published a report – Insurance Distribution Directive – Evaluation of the Structure of Insurance Intermediaries Markets in Europe – together with an annex containing a Country-by-Country Analysis.

Although national variations in registration practices, reporting frameworks and categories of intermediaries hampered the ability of EIOPA to draw conclusions on the intermediary market at a European level, it was able to identify some trends including significant variations in the size of insurance intermediaries markets and a small decrease in the number of registered intermediaries (primarily natural persons and agents) which may be due to more stringent regulatory requirements and the growth of alternative distribution channels.  It notes also that there is a small but increasing role of direct insurers in distribution, particularly on the life side. Although the data is patchy, it appears that cross-border business is increasing. Remuneration models are predominantly either commission based (majority) or fee based.

In Ireland, EIOPA’s analysis revealed a period of contraction in the number of regulated firms in the last number of years but an increase in the number of Managing General Agents.  Notifications from intermediaries intending to carry out cross-border business have also increased.  According to the data, there are approximately 2,200 regulated insurance intermediaries in Ireland (excluding credit institutions and credit unions) of which 92% have less than 10 employees and 46% have only one employee.  Estimates by the Central Bank indicate that 51% of all insurance products sold by Irish authorised insurers or insurers authorised in another Member State with a branch in Ireland, are sold through insurance intermediaries.

This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.