EFAMA welcomes the opportunity to comment on EIOPA’s draft suggestions for the technical implementation of the Insurance Distribution Directive (IDD).
We agree with the approach described in the Commission’s mandate that alignment with the MiFID II regime should be sought in every area in which there is no fundamental difference in the wording of the parallel provisions in the IDD and MiFID II. We agree that, given the substitutability of products covered by IDD and by MiFID II, the starting point should be alignment between the two sets of requirements unless differences in the Level-1 texts exist and there are clearly justifiable reasons for reasons of investor protection to create diverging approaches. In our view, the draft Technical Advice presented by EIOPA strikes the right balance between accounting for peculiarities of insurance products and distribution models on the one hand and striving for consistency with MiFID II in specific wording, or at least in the quality of regulation, on the other. We highly appreciate the efforts dedicated to this challenging exercise and strongly support and encourage EIOPA to remain committed to this general approach.