Verband der Versicherungsunternehmen Österreichs / Austrian Insurance Association
VVO
Der Verband der Versicherungsunternehmen Österreichs (VVO) vertritt die Interessen aller in Österreich tätigen privaten Versicherungsunternehmen und unterstützt seine Mitglieder bei rechtlichen, steuerlichen, wirtschaftlichen und internationalen Angelegenheiten.
ID: 278435521661-59
Lobbying Activity
5 Sept 2025
We fully support the position of Insurance Europe.
Read full responseResponse to Claims history statement template for motor insurance
23 Feb 2024
Please find attached our feedback on the draft implementing regulation regarding the template for the claims history statement (CHS) in motor insurance. We support the Insurance Europe response to the draft implementing regulation regarding the template for the claims history statement (CHS) and want to particularily emphasize certain aspects of it.
Read full responseResponse to Retail Investment Package
31 May 2022
The Call for Evidence does not detail the magnitude of the problems identified or the concrete proposals under consideration. We are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear making it is difficult to provide meaningful feedback.
We would like to set out the following considerations that the EC should focus on in devising its new retail investment strategy (RIS) to ensure its success:
Fully evaluate existing legislation:
The IDD is robust and provides a very high level of consumer protection, including on remuneration, advice and advisor competence. The minimum harmonization approach makes it possible to impose further measures when needed to reflect national markets .
The IDD has only been in application since Oct 2018, but in some cases, transposition only occurred over the past year. EIOPA concludes in its report on the application of the IDD that: “It will be important to reassess the application of the IDD at later stage, prior to proposing any major changes to the legal framework.” Only make changes to address a clear identified need
Changes to the existing regulatory framework result in costs which ultimately are born by consumers. Amendments must be proven to provide value for the consumers to justify these costs.
A cost/benefit analysis should be undertaken for new regulatory initiatives, particularly relating to changes to disclosure – it is well known that simply providing more and more documentation for consumers does not increase engagement in financial decisions.
The most immediate need is for targeted modifications of IDD and essential changes to PRIIPs Level 1 to avoid overwhelming consumers with duplicative information, allow digital disclosures and properly represent insurance features in the KID.
Focus on the needs of consumers:
Consumers need simpler and more engaging disclosures. EIOPA’s included helpful proposals in their advice to the EC on digitalisation and avoiding duplication, however, adding an annual statement on top of the information received by consumers or further figures on costs and performance in the KID, would worsen information overload.
To help consumers understand product features disclosures must specifically highlight whether or not the product offers insurance benefits. The KID should prominently display the existence or lack of insurance cover, guarantees or other benefits. This should be the purpose of the dashboard proposed in the ESAs’ advice to the EC and can only be achieved through changes to the PRIIPs Level 1.
Understand the differences between different markets and products:
As a major provider of PRIIPs, insurers are key to the RIS. IBIPs are long-term and can combine investments with insurance cover. This increases consumer protection and must be recognised in distribution and disclosure rules.
Regulation should not impede the ability of insurers to design and distribute new products in accordance with consumers’ demands and needs.
Distribution systems are also varied. The IDD works well because it respects this, with the commission model being the predominant one across the EU.
Test the impact of changes before implementation:
Extensive consumer testing must be conducted by the EC before implementing changes. For example, testing would not show any benefit of the EC’s proposals on a new suitability assessment. It would be unworkable for insurers and cause significant problems for customers by restricting their choice of products, limiting their access to quality advice, and forcing advisers to offer products based on irrelevant criteria. Concerns have been expressed by market participants and ESMA in its letter to the EC.
Any changes to disclosures would also need thorough testing, including retesting of the final requirements, if changes are made during the legislative process!
Read full responseMeeting with Kyriacos Charalambous (Cabinet of Vice-President Johannes Hahn)
21 Feb 2019 · to discuss Western Balkan insurance market
Response to DA on conduct of business rules for the distribution of insurance-based investment products
17 Aug 2017
VVO remarks on the Delegated Act on Insurance-Based Investment Products
General comments
The recitals mention several times that this delegated act corresponds with the standards set out under MiFID II. However, it should be duly noted that the adoption of a sectoral insurance distribution directive is based on the regulatory objective to respect the specificities of insurance products. An essential cornerstone for the proper functioning of insurance markets is the recognition of the interests of the community of the insured.
Also in case of insurance-based investment products this specificity should be respected.
EIOPA did so in its Technical Advice on page 36 no. 7:
„EIOPA acknowledges that the management of conflicts of interest, in particular those that arise between customers, should be undertaken in a way which takes into account the basic principles in insurance, in particular the principles of solidarity, risk pooling and mathematical methods.“
The Delegated Act on insurance-based investment products should contain such a provision, in order to respect the interests of the community of insured, which is automatically joined by each new customer by purchasing an insurance product. This shall ensure the long term functioning of the insurance product.
Read full responseResponse to DA on product oversight and governance requirements for insurance undertakings and insurance distributors
17 Aug 2017
VVO remarks on the Delegated Act on product oversight and governance (POG)
General comments
The Austrian insurance industry welcomes the current version of the delegated act as it reflects the principle of proportionality in several aspects. This ensures that the complexity and the features of an insurance product including its potential consumer detriment are appropriately taken into account.
From our point of view the delegated act should duly consider, that the customer joins a community of insured when buying an insurance product, which can only deliver its outcome in case the interests of the collective of policyholders are taken into account. Respecting the colective interests also benefits the individual member of the community of insured.
EIOPA fully respected the relationship between individual and collective policyholder interests in its Technical Advice on possible Delegated Acts concerning the IDD of 1 February 2017 (EIOPA-17/048) in point 16 of its analysis (page 13):
„Product oversight and governance arrangements are without prejudice to basic principles in insurance, in particular the principles of solidarity, mathematical methods and risk pooling. The interests of customers that need to be taken into account when designing products following the product oversight and governance arrangements, comprise individual and collective policyholder interests which need to be duly balanced.“
The Delegated Act should also provide for such a provision either under Chapter 1 (General Provisions) or at least in the form of a recital, in order to ensure a safe and sound functioning of the risk community which is essential to insurance markets.
On Art. 7 (Product monitoring and review)
Following the last sentence of paragraph 3 product manufacturers shall inform customers promptly about any remedial action taken.
The VVO (Austrian Insurance Association) would like to underline that potential customer detriment detected during product oversight and governance may result from very different factors. Accordingly also the remedial action taken may vary in its importance from customer to customer. Therefore distributors and customers shall be informed where this is relevant for the customer in terms of the nature of the detriment and the general impact of the remedial action.
Therefore EIOPA proposed the following wording in its Technical Advice on page 29 no. 24:
„If relevant, the manufacturer shall notify any relevant remedial action promptly to the distributors involved and to customers.“
The last sentence of paragraph 3 should follow EIOPA’s technical advice and read as follows:
„If relevant, manufacturers shall promptly inform concerned insurance distributors and customers about the remedial action taken.“
On Art. 10 (Product distribution arrangements)
Following paragraph 1 insurance distributors shall have distribution arrangements in place containing appropriate measures and procedures to obtain from the manufacturer all appropriate information on the insurance products.
Such arrangements are deemed of no relevance where the product manufacturer distributes his products via his own employees.
Paragraph 1 should read as follows:
„Insurance intermediaries shall have …“
Read full response