IDD monitoring
in a single inbox.
The IDD (Directive (EU) 2016/97) has been in force since October 2018, but the supervisory pressure has shifted from "is the regime implemented?" to "are insurers actually documenting demands-and-needs and POG decisions defensibly?". EIOPA's third application report is expected in 2026; POG-related Q&As keep landing; national supervisors (BaFin, FMA, ACPR, IVASS, DGSFP) publish their own circulars on conflicts of interest and inducement disclosure. Horizon Scanner watches every source and routes findings to product governance, distribution and compliance.
Scope
What IDD covers — and what we crawl for it.
Directive 2016/97 and Member-State transpositions
The IDD itself plus every Member-State transposition act and amending decree. National gold-plating — e.g. BaFin's commission caps for life products, ACPR's IPID supplements — is surfaced explicitly.
POG Delegated Regulation (CDR (EU) 2017/2358)
Product Oversight and Governance obligations on manufacturers and distributors — target-market identification, product-testing, distribution-strategy adequacy, regular review. EIOPA POG-related Q&As cross-referenced.
IPID format (CIR (EU) 2017/1469)
Insurance Product Information Document — standardised pre-contractual disclosure for non-life products. Implementing Regulation 2017/1469 sets the format; national supervisors publish translations and sector-specific clarifications.
Demands-and-needs test (Art. 20)
Article 20 demands-and-needs test plus the personalised recommendation requirement. Supervisory expectations around digitalisation of advice, robo-advice, and execution-only carve-outs.
IBIPs — insurance-based investment products
Articles 29–30 specific obligations for IBIPs: suitability and appropriateness assessments, inducements rules, conflicts-of-interest management. PRIIPs KID cross-references.
EIOPA application reports and Q&As
EIOPA's IDD application reports (2019, 2022, expected 2026) and ongoing Q&A entries — the de-facto Level-3 source on interpretation. Diff-tracked when answers change.
How Horizon Scanner helps
Specifically for IDD teams.
- 01
Filtered by product line
Configure your IDD product lines — life, non-life, IBIPs. A non-life-only distributor doesn't see IBIPs-specific inducements rules; a life-only manufacturer doesn't see motor-insurance IPID variations.
- 02
POG decision-evidence tracker
Every POG-relevant Q&A update or supervisor letter is tagged against the manufacturing or distribution decision it affects (target-market, testing, review cycle). Useful when a supervisor asks why a decision was made on a given date.
- 03
Routes to product, distribution, compliance
Default routing: POG-related items to the product-oversight function, IPID format updates to product, demands-and-needs Q&As to the distribution lead, inducements / conflicts findings to compliance.
- 04
Cross-cuts with AML and DORA
IBIPs distribution touches AML (especially for life products); the distribution channel's ICT systems touch DORA where the insurer relies on a distribution platform. Cross-tags surface the overlaps so the right teams meet.
Sources monitored
The regulators we crawl for IDD.
- EIOPAIDD application reports, POG- and IBIPs-related Q&A entries, opinions, supervisory convergence reports.
- EUR-LexDirective (EU) 2016/97, CDR (EU) 2017/2358 (POG), CIR (EU) 2017/1469 (IPID), all amending acts and consolidated versions.
- BaFinVersVermV regulation, MaGo-IDD elements, BT-7 of MaRisk-VA, German IDD-implementing rules. Commission-cap and inducements interpretive guidance.
- FMA (AT)FMA-Mindeststandards on insurance distribution, supervisory letters on POG and demands-and-needs, sectoral statistics.
- ACPRACPR recommendations on IDD application in France, market-conduct supervisory letters, IPID-translation supplements.
- IVASSItalian implementation of IDD, supervisory regulations on distribution, POG and conflicts of interest.
- DGSFPSpanish IDD-transposition rules, market-conduct supervision letters, distribution-related circulars.
- DNB / AFMDutch dual-peak supervision: AFM on conduct of business (distribution, POG, IPID), DNB on prudential aspects.
Custom sources can be added in minutes — supervisory blog feeds, association circulars, internal counsel memos all route through the same engine.
FAQ
What IDD buyers ask first.
How do you track national gold-plating without drowning the inbox?
Each national rule is tagged with both the IDD article it implements and the jurisdiction. Groups operating across multiple Member States can subscribe per subsidiary to filter to local rules; the EU-level finding is shared once across all subscribers with deduplication.
Can sub-teams subscribe to POG only without seeing IBIPs items?
Yes. Subscriptions can be scoped down to individual IDD articles or sub-topics. A POG-only team subscribes to Article 25, CDR 2017/2358, and POG-related EIOPA Q&As; IBIPs items (Articles 29–30) route to the IBIPs team instead.
What about the 2026 EIOPA application report — will scope automatically broaden?
When EIOPA publishes the third application report, its recommendations become tracked items. If the Commission proposes amendments in response, those proposals enter the routing engine as Level-1-amendment items, separately from existing IDD provisions, so your team sees the delta clearly.
Do you handle the IDD-MiFID II overlap for IBIPs?
Yes. IBIPs distribution sits at the IDD-MiFID II boundary — Article 30 IDD vs. MiFID II suitability/appropriateness. Findings touching both regimes are dual-tagged. The routing engine can send the IDD-side to insurance distribution and the MiFID-side to investment-services without duplicating the audit trail.