IVASS amends regulations to simplify pre-contractual information

On 20 June 2024, IVASS issued Order no. 147/2024, revising the provisions concerning pre-contractual information outlined in IVASS Regulation No. 40/2018 and 41/2018.

The new provisions aim to enhance the effectiveness of information provided to policyholders by simplifying documents, ensuring they’re clear, comprehensive and concise. They should also better protect policyholders throughout their relationship with distributors.

These measures emphasize the need for contracts and documents to be clear and complete. They also try to ensure consistency between pre-contractual information and general contract terms, especially regarding key clauses. The new rules also aim to reduce organizational burdens on distributors and ensure alignment with evolving European and national regulations on sustainable finance.

Let’s look at the most relevant amendments.

Amendments to IVASS Regulation no. 40/2018: New templates for intermediaries

• Unified Pre-Contractual Model (Modello Unico Precontrattuale – MUP): all pre-contractual information from the distributor has to be provided in a unified format, differentiated based on the type of product distributed (IBIP and non-IBIP), replacing Annexes 3, 4, 4-bis and 4-ter.
• Frequency of updating pre-contractual documents: during renewal or when concluding a new contract, distributors have to provide or send the information specified in the MUP only in the event of significant changes.
• Direct distribution: insurers can now directly deliver the required pre-contractual documents in the event of direct distribution.

Amendments to IVASS Regulation no. 41/2018: Changes to the Additional IPID

Simplification of Additional IPID: three new formats (life, non-life, motor liability, and multi-risk insurance) have been introduced, focusing on insurance covers, exclusions and limitations, target clients, costs, mandatory information pursuant to Article 185 of the Insurance Code (solvency, claims, applicable law), and the tax regime.

Coordination among policy documents: the new Additional IPID for IBIPs will now be coordinated with the KID, promoting a synergistic reading of the two documents and facilitating the comparability of IBIPs with other products.

Page Limit: there’s now a maximum page limit of three pages for the Additional IPID.

 

Sustainable finance

The measure completes the adjustments needed to comply with European regulations on sustainable finance in IVASS’s regulatory provisions, continuing the effort that began with Measure No. 2023/131.

Specifically, it aims to:

• incorporate updates introduced by the Regulatory Technical Standards (RTS) specified in Delegated Regulation (EU) No. 2022/1288, and further detailed in subsequent Delegated Regulation (EU) 2023/363; and
• ensure alignment with distributor disclosure requirements (Regulation No. 40/2018) and achieve similar alignment with manufacturer disclosure requirements (Regulation No. 41/2018).

 

Timeframe

Within 12 months, companies and distributors must prepare the Unified Pre-contractual Module (MUP) for IBIP and non-IBIP products, as well as Additional IPID for life, non-life, motor liability, IBIP and multi-risk insurance products.