Insurance Europe has today published its response to the European Commission’s roadmap consultation on the Distance Marketing Directive (DMD).
Serious consideration must be given to whether the DMD remains relevant and adds value, in light of several more recent product-specific EU rules, such as the Insurance Distribution Directive.
In particular, insurers have concerns about overlap between these texts and the lack of legal certainty over which text takes precedence. Insurers take the view that product-specific legislation should take precedence, if the DMD is to be retained. Furthermore, if the DMD is retained, it must also be digital neutral.