This site uses cookies to provide you with a more responsive and personalized service. By using this site you agree to our use of cookies. Please read our cookie notice for more information on the cookies we use and how to delete or block them.

Bookmark Email Print page

IMD II / PRIPS / Supervision of Insurance - 26/09/2012


The European insurance distribution landscape will change in the coming years due to current directives reforms.

The current reforms articulated around PRIPS and IMD II will impact the entire value chain including insurers, intermediaries and customers.

PRIPs proposes the introduction of the Key Information Document (KID) when investment products are sold to retail consumers. IMD II proposes to widen the scope of the Directive and strengthen conduct of business and professionalism requirements for intermediaries and direct sales.

In this context, EFAMA has published his comments on the European Commission proposal for a Regulation of the European Parliament and of the Council on key information documents for investment products and on insurance mediation.

The comments expressed by EFAMA relate to the clarification some aspects of the EC proposal as well as amendments in order to achieve, in the view of EFAMA, the desired level playing field across all investment products. Key comments pertain to the scope and the content of KID as well as its legal status and level 2 measures.

In essence and in addition to the set of comments on the EC proposal, the views of EFMA are as follows:

  1. EFAMA is supportive of the objectives of the EC to align the regulation of marketing and selling practice for all types of PRIPs across the Union,
  2. EFAMA believes that MiFID and IMD rules should be aligned and debated in parallel with a consistent calendar,
  3. EFAMA favors the idea that to ensure comparability for all retail investors, IMD PRIPs and MiFID shall altogether form a “whole of the market” set of rules.

You will find below the links to the documents to the EFAMA comments.

We trust this information is of assistance and remain at your disposal for any further questions.

Page Last Updated


Thierry Flamand
Deloitte Luxembourg
Job Title:
Partner - Actuarial & Insurance Solutions
+352 451 454 920
Jérôme Lecoq
Deloitte Luxembourg
Job Title:
Partner - Audit
+352 451 452 623



Stay connected:
Get connected
Share your comments
More on Deloitte Luxembourg
Learn about our site

Recently published