In 2024, the Institute for Insurance Supervision (IVASS) introduced Provision No. 147 of June 20, 2024, aimed at simplifying and streamlining pre-contractual and contractual information in the insurance sector.
1. Introduction of the Single Pre-Contractual Form (MUP)
The provision introduces the Single Pre-Contractual Form (MUP), a modular document tailored to the product type (IBIP and non-IBIP), consolidating all pre-contractual information required by the Private Insurance Code (CAP). The goal is to avoid information fragmentation and provide customers with clear and comprehensive information.
2. Documents Replaced by the MUP
The adoption of the MUP leads to the repeal of the following annexes of IVASS Regulation No. 40/2018:
– Annex 3: Distributor Information;
– Annex 4: Insurance distribution information for non-IBIP products;
– Annex 4-bis: Distribution information for insurance investment products;
– Annex 4-ter: List of distributor conduct rules.
These documents had become formal requirements without adding tangible value for consumers.
3. Structure of the MUP
The MUP is divided into seven sections, including:
– General information about the distributor;
– The adopted distribution model;
– Potential conflicts of interest;
– Consulting services offered;
– Distributor remuneration;
– Insurance product information;
– Policyholder rights and obligations.
This approach aims to provide the customer with a comprehensive and easily understandable overview of the necessary information before signing a proposal or concluding a contract.
4. Changes to Additional Pre-Contractual Information Documents (DIPs)
The provision also redefines the structure of additional Pre-Contractual Information Documents (DIPs), originally designed to complement the content of DIP/KIDs. The informational scope of these documents is reduced, focusing on essential information such as:
– Costs;
– Exclusions and limitations;
– Target customer;
– Tax regime.
Additionally, a three-page limit is introduced for additional DIPs, extendable to four in exceptional and justified cases, ensuring conciseness and clarity.
5. Alignment with European Sustainable Finance Regulation
Provision No. 147/2024 aligns Italian legislation with European provisions on sustainable finance, particularly Regulation (EU) 2019/2088. Insurance companies are required to make available, where relevant, the periodic information provided under Article 11 of the aforementioned regulation, ensuring transparency on the sustainability characteristics of the products offered.
6. Implications for Companies and Distributors
Insurance companies and distributors will need to comply with the new provisions by translating the guidelines into documentation and information sets that aim for transparency and clarity, benefiting consumers. This requires a review of internal processes and updates to operational procedures to align with the new regulations. The recipients of Provision 147/2024 will have one year from its effective date to comply and prepare the new disclosures, with a deadline set for June 2025.
7. Conclusion
IVASS Provision No. 147/2024 represents a significant step toward simplifying and streamlining pre-contractual and contractual information in the insurance sector. The introduction of the MUP and the redefinition of additional DIPs aim to provide consumers with clearer and more concise information, facilitating informed decision-making for insurance products. Simultaneously, alignment with European sustainable finance regulations highlights the industry’s commitment to more transparent and responsible practices.
EXP Legal is available to assist companies and professionals in adapting to the new regulatory provisions and implementing strategies aligned with recent developments in the insurance sector. Contact us for personalized consulting.