IDD — Insurance Distribution Directive
Directive 2016/97/EU on insurance distribution. POG, demands and needs test, conflicts of interest, continuous IDD training, target market.
What is IDD and who does it apply to?
IDD (Insurance Distribution Directive) is EU Directive 2016/97 regulating insurance product distribution in the EU. In Italy transposed by Legislative Decree of 21 May 2018 no. 68, implemented by IVASS Reg. 40/2018. It applies to all entities distributing insurance products: insurers, brokers (RUI section B), agents (section A), banks and postal institutes (section D), occasional intermediaries (section E), comparison portals. The core of IDD are 4 operational duties: POG (product oversight governance), demands and needs test, conflict-of-interest management, continuous training. NewPicass 14.Net implements all four as native workflow in the policy-issuance process.
IDD articles that become software workflow
D&N test
Demands and Needs test
Mandatory pre-issuance questionnaire with logged product-choice rationale. Implemented in NewPicass issuance form as blocking step.
IVASS Reg. 38
POG
Product Oversight Governance
Positive + negative target market, product testing, continuous monitoring. Analytics module produces target-market adherence reports by product and segment.
IVASS art. 67-72
Conflict of Interest
Per-intermediary conflict register, automatic identification in issuance form, mandatory customer disclosure with sign-off.
Reg. 40/2018
15h/year continuous training
Training tracker: per-operator training profile, annual-hour monitoring, pre-deadline reminders, archived certificates for IVASS audit.
Disclosure
Pre-contractual disclosure
IPID (Insurance Product Information Document), advice type, costs and charges. Auto-generated by back-office and customer-signed.
What NewPicass 14.Net does vs what remains yours
Covered by the platform
- D&N test workflow in issuance form
- Automatic IPID generation
- Per-intermediary conflict register
- Training tracker with annual IDD hours
- Per-product target-market adherence reports
- Issuance-decision audit trail
- Conflict-of-interest disclosure workflow
- IDD-compliant customer portal for online sale
Customer responsibility
- Positive/negative target market definition
- Internal product approval process
- Conflict management policy
- Delivery of IDD training to own intermediaries
- Decision on mis-selling vs physiological deviation
- Annual report submission to IVASS
- POG update on new products
Where this framework lives in the platform
Frequently asked questions on IDD
What does POG (Product Oversight Governance) mean?
POG is the process required by IDD art. 25 + IVASS Reg. 38/2018: for each insurance product you must (1) define a "positive" target market (the typical customer the product fits) and "negative" (who it does NOT fit); (2) test the product before commercialisation; (3) continuously monitor product performance on the actual target market; (4) intervene if deviations emerge (mis-selling, anomalous loss ratio on segments).
What is the "demands and needs test"?
IDD art. 20 §1 requires that, before any insurance contract is concluded, the intermediary collects information from the customer on their "demands and needs" and proposes a consistent product. Operationally: structured pre-issuance questionnaire, logged product-choice motivation, possibility to refuse coverage with documented reasoning. NewPicass 14.Net implements the workflow within the issuance flow.
How are conflicts of interest handled?
IDD art. 28 + IVASS art. 67-72 Reg. 40/2018 require identification, management and disclosure of conflicts of interest. NewPicass maintains a per-intermediary conflict register (e.g. delegating-insurer ownership stakes, commercial agreements, incentives), automatically flags conflict situations in the issuance form, requires customer disclosure before signing.
Is continuous IDD training tracked?
Yes. Integrated training-tracker module: each operator has a training profile with mandatory yearly IDD hours (15h/year for registered brokers/agents per art. 90 IVASS Reg. 40), attended courses, certificates. Automatic reminder 60 days before annual deadline. IVASS-audit-ready reporting on request.
What about periodic target-market reporting?
For products you designed/co-designed (e.g. insurer or MGA), the Analytics module produces periodic target-market adherence reports: actual customer distribution by size, sector, geography, tenure, vs target declared at POG stage. Alerts on significant deviations (potential mis-selling). Input for the periodic review required by IDD.
Does IDD also apply if I sell policies online?
Yes. IDD is channel-agnostic: whether you sell via physical agent, broker, web comparator, app — POG, demands and needs, disclosure obligations are the same. The NewPicass white-label customer portal includes an IDD-compliant workflow: demands/needs questionnaire before online purchase, conflict disclosure, customer-choice log with timestamp.
Audit your IDD compliance with us
45 minutes with a compliance engineer. We walk through the platform's coverage on this framework and identify the gaps you still need to close on your side.