IVASS Provision 147/2024 – Amendments to the regulations on insurance product distribution and pre-contractual information

With Provision 147/2024 dated June 20, 2024, IVASS has introduced significant amendments to:

  • Regulation 40/2018, laying down provisions on insurance and reinsurance distribution;
  • Regulation 41/2018, on transparency, disclosure, and design of insurance products.

IVASS acknowledged that the current provisions on distribution and pre-contractual disclosure have increased significantly the costs for operators to provide the information required but have not strengthened the effectiveness of such information.

Among the main issues, IVASS has identified: (i) an excessive number of forms delivered to the Client; (ii) a partial duplication of the same content; (iii) an excessive length of additional DIP; (iv) the overlap of information present in additional DIP and in DIP or KIDs.

IVASS has, therefore, intervened with Provision 147/2024 to simplify and streamline the existing regulations.

Following the amendments to Regulation 40/2018:

  1. the Single pre-contractual form (MUP) for insurance products;
  2. and the Single pre-contractual form (MUP) for insurance investment products,

Have replaced Annex 3 (distributor Information), Annex 4 (Information on the distribution of non-IBIP insurance products), Annex 4-bis (Information on the distribution of insurance investment products), and Annex 4-ter (List of distributor conduct rules).

Regarding Regulation 41/2018, the amendments made by the Provision aim to:

  1. simplify the structure of DIP by eliminating redundant elements;
  2. introduce a page limit (no more than 3) for the drafting of additional DIP;
  3. for IBIPs, standardize the nomenclature between additional DIPs and KIDs.

Companies will have 12 months from the entry into force of Provision 147/2024 to comply with the introduced amendments.