Market access

What type of activity is “insurance distribution”?

Insurance distribution activity covers a wide range of activities.  As defined by the Insurance Distribution Directive, insurance distribution means:

The activities of advising on, proposing or carrying out other work preparatory to the conclusion of contracts of insurance, of concluding such contracts, or of assisting in the administration and performance of such contracts, in particular in the event of a claim, including the provision of information concerning one or more insurance contracts in accordance with criteria selected by customers through a website or other media and the compilation of an insurance product ranking list, including price and product comparison, or a discount on the price of an insurance contract, when the customer is able to directly or indirectly conclude an insurance contract using a website or other  media.’

Where a UK intermediary has engaged an appointed representative to act on their behalf, the broker is responsible for anything done or omitted by the appointed representative in carrying on the business for which the broker has accepted responsibility. This includes any activity that may be impacted by the end of the transition period.

Appointed representatives should only perform certain regulated activities which fall within the scope of their principal’s permissions and which have been delegated to them.  UK intermediaries might wish to consider reviewing the activities that appointed representatives are conducting on their behalf and assess whether any modifications or changes might be required to ensure that their appointed representative does not perform activities which fall outside the scope of their principal’s permissions at the end of the transition period.

Where a firm has been engaged by another firm to be its appointed representative, the principal is responsible to for anything done or omitted by the appointed representative in carrying on the business for which the broker has accepted responsibility. This includes any activity that may be impacted by the end of the transition period.

Appointed representatives should only perform certain regulated activities which fall within the scope of their principal’s permissions and which have been delegated to them under a written agreement.  Firms might wish to consider reviewing the activities that they have been performing to date and discuss with their principal how their permissions might be affected by the end of the transition period.