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BIPAR - European Federation of Insurance Intermediaries

BIPAR

In accordance with our bylaws, the objectives of BIPAR are: 1) to represent the profession and the sector with the European, international or national authorities, institutions and organisations and to provide them with input; 2) to defend and promote the interests of the profession and of the sector and to take actions to this end with the European, international or national authorities, institutions and organisations; 3) to exchange information between its members; 4) to examine jointly subjects of general interest; 5) to inform the public on the role of its members. BIPAR is the European Federation of Insurance Intermediaries. It groups 47 national associations in 30 countries. Through its national associations, BIPAR represents the interests of insurance agents and brokers and financial intermediaries in Europe.

Lobbying Activity

Response to European climate resilience and risk management law

4 Sept 2025

BIPAR welcomes the opportunity provided by the European Commission to comment on its call for evidence on a European climate resilience and risk management initiative. BIPAR commends the European Commission for committing to strengthen the resilience of EU Member States, their economies and societies, their citizens and businesses to the increasing risk of natural disasters and to deliver the comprehensive framework and plan for action this urgently requires. We believe that the framework and action plan should use the proposed actions and good practices put forward by the EC Climate Resilience Dialogue in its July 2024 Final Report in order to narrow the climate protection gap. BIPAR was part of this dialogue and welcomed the report as a useful and powerful piece of work. Insurance intermediaries can play a pivotal role in contributing to climate adaptation, as many have expertise in the modelling of climate risk and the development of resilient and sustainable business models. Intermediaries can also have a key role in raising awareness of climate risks, in covering new risks (especially for SMEs), preventing a possible "protection gap/insurance gap" by developing adapted and innovative insurance solutions. Levering the findings of the Report and fully considering the principles of proportionality and subsidiarity, we believe that the European Commission should in particular focus on raising risk awareness, on financial education and customer support, on risk transfer such as public-private partnerships and other insurance-based solutions. BIPAR would like to draw the attention to a key point of the EC Climate Resilience Dialogue Report: it underlines the importance of an adequate legal and regulatory framework that could allow innovation and encourage SMEs and consumers to purchase climate- related insurance. ( see annex)
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Meeting with Yann Germaine (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)

18 Jul 2025 · Exchange of views on a potential harmonisation of Insurance Guarantee Schemes (IGS)

Response to Recommendation on savings and investment accounts

7 Jul 2025

Please find attached the BIPAR answer to the EC Call for Evidence on the Recommendation on savings and investment accounts.
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Meeting with Alberto Fernandez Diez (Cabinet of Commissioner Marta Kos) and Afore Consulting and Lloyd’s Insurance Company SA

24 Jun 2025 · Dinner Invitation with Lloyd's on Ukraine Reconstruction

Response to Revision of EU rules on sustainable finance disclosure

29 May 2025

Please see the attached document.
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Response to Savings and Investments Union

28 Feb 2025

See attached file.
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Meeting with Billy Kelleher (Member of the European Parliament)

18 Nov 2024 · Insurance Brokers

Meeting with Ondřej Kovařík (Member of the European Parliament, Shadow rapporteur)

25 Jan 2024 · FIDA

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur) and Planète CSCA

20 Dec 2023 · Retail investment strategy

Response to Rationalisation of reporting requirements

1 Dec 2023

Please find our input attached.
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Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

22 Sept 2023 · Retail investment strategy

Response to Retail Investment Package

28 Aug 2023

Please find attached BIPAR feedback
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Meeting with Alfred Sant (Member of the European Parliament)

21 Jul 2023 · Retail Investment Strategy Proposal

Meeting with Mairead McGuinness (Commissioner) and

18 Jul 2023 · Distribution of Retail financial products

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness)

13 Feb 2023 · Retail investment strategy

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

13 Feb 2023 · Retail investment strategy

Response to Retail Investment Package

31 May 2022

BIPAR welcomes the opportunity to comment on the European Commission’s Call for evidence for an evaluation and impact assessment run in parallel regarding the Retail Investment Package initiative. In line with previous BIPAR input provided on the same issue at the occasion of other Commission/ESAs consultations, please find attached BIPAR comments.
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Meeting with Billy Kelleher (Member of the European Parliament, Rapporteur)

25 Oct 2021 · DORA

Response to Revision of EU rules on Anti-Money Laundering (new instrument)

18 Oct 2021

BIPAR endorses the EU’s aim to improve the detection of suspicious transactions and activities, and to close any loopholes used to launder illicit proceeds or finance terrorist activities through the financial system. BIPAR believes that in the EU AML regulatory framework maximum/total harmonisation would not be consistent with the risk-based approach followed by regulators and supervisors at international and EU level and implemented at the financial services sector, including insurance and financial intermediaries. It is essential that the EU regulators and supervisors take into account the differences in AML/CTF risk exposure undertaken by various obliged entities. For the proportionality principle to apply in practice (without loss of efficiency in terms of risk), a “lighter” regime or exemption may be introduced for specific situations which will take into consideration the stream of activities in order to avoid duplication or triplication of work. Member States and AML rules should continue to consider the differences between sectors and specific products within the financial services sector and the range of different actors carrying out activities within the same sector. This way, implementation of the (new) AML rules will be promoted, and they will not end up being just an administrative burden and extra costs for the obliged entities, particularly for SMEs. It is therefore crucial that, while preparing any new AML rules, the implementation of the existing AML rules based on the proportionality principle and the risk-based approach is ensured. For SMEs one of the major issues is the fact that if they are in administrative breach of one of the rules, they are exposed to very heavy legal defence costs which are proportionally bearable by large structures. In particular, concerning intermediation activities we are of the opinion that the regulation should allow for “agreements” which allow the parties to rely on other parties for the required AML checks and procedures and/or to continue and outsource functions. This would improve efficiency. In summary, the key BIPAR messages are the following: - Risk-based approach and proportionality principle should apply to the greatest possible extent with regards to the CDD measures, beneficial ownership rules, etc, in order to take account of the size, nature, complexity and the risk of the activities in question and allow for a level-playing field. - Exemption for pure life insurance products and certain types of life insurances with capital guarantees (and a fiscal long-term treatment) with extremely low risk should be considered. - Life insurance products intermediated by an intermediary should not pass through the same AML checks more times than necessary. - Occupational pensions distributed by insurance intermediaries/companies should be exempt from the scope of the AML rules. The risk is extremely low. - SME insurance intermediaries should not be obliged to appoint AML/CTF compliance officer. A differentiating approach is needed regarding the obligation to appoint an AML/CFT compliance officer based, not only on the size, but also on the low ML risk exposure of the entity in question. - Outsourcing of AML/CFT compliance function should be always allowed. The possibility to outsource the tasks of the AML/CFT compliance officer/ function should be given. - BIPAR does not agree with prohibiting the outsourcing of the internal controls and the attribution of a risk profile to a prospective client. While the ultimate responsibility must remain with the obliged entity, insurance intermediaries and particularly SMEs will face a really heavy burden if they are not able to outsource such functions. Outsourcing possibility will create efficiency. - Consumer credit intermediaries should be exempted from the scope of AML rules. -AML Supervisory Authorities should be careful not to follow an “one size fits all” approach and to integrate proportionality in their supervision.
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Response to Distance Marketing of Consumer Financial Services - Review of EU rules

25 Jun 2021

Please see attached BIPAR response to the Commission consultation on Distance marketing of consumer financial services – review of EU rules
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