Entry into force IDD

On 1 October 2018, the Dutch implementation law and the Dutch implementation Decree of the Insurance Distribution Directive (IDD) have entered into force. As a result, the IDD has now been implemented and is in force in the Netherlands.

The implementation of the IDD has resulted in various changes in the Dutch rules for insurers, intermediaries and advisors:

• Some of the existing exemptions and exceptions have been amended. Also, the implementation of the IDD has introduced a new exemption possibility for parties that provide intermediary services with respect to insurance contracts that are ancillary to the delivery of a good or service (such as travel agencies and car rental companies).
• Also, the IDD has introduced rules on cross-selling. If in addition to an insurance contract, the client gets offered an ancillary service or good, cross-selling is in principle allowed but the client needs to be informed about the connection between the two. However, if it is the insurance contract that is ancillary to a service or good, cross-selling is prohibited. In such case, the client needs to be offered the possibility to purchase the good or service also without the insurance contract.
• The IDD has introduced new information requirements when offering non-life insurance contracts. Clients will benefit from a simple, standardised insurance product information document (the Insurance Product Information Document, IPID), which aims to provide clearer information on non-life insurance products, so that consumers can make more informed decisions.
• Finally, the implementation of the IDD has also sharpened some existing rules with respect to product governance and has also introduced some new rules in this respect.

The IDD has mainly been implemented in the Dutch Financial Supervision Act (Wet op het financieel toezicht) and the Decree on Conduct Supervision financial institutions (Besluit Gedragstoezicht financiële ondernemingen Wft).