Consob, the Italian financial sector regulator, has launched a consultation on the abrogation of the obligation to publish a prospectus for unit-linked and index-linked insurance products.
The proposed change is intended to end the peculiar Italian regime requiring insurers to draft a prospectus for unit-linked and index-linked insurance products, introduced in 2005 when the EU legal framework on pre-contractual information for insurance products was far from harmonized.
The consultation follows the introduction throughout the EU of the key investor information document (KIID) for insurance based investment products which is broader in scope than Italy’s prospectus regime. It also comes slightly after the launch of a broader consultation by IVASS, the Italian insurance regulator, aimed inter alia at reshaping pre-contractual disclosure in the insurance sector in connection with the transposition of the Insurance Distribution Directive (IDD).
In connection with the measures approved by the Italian Government and the current consultation by IVASS on IDD implementation, the overall set of documents for insurance based investment products will be composed of:
- a KID, in accordance with Packaged Retail and Insurance-based Investment Products Regulation, and
- an additional insurance product information document, again as a purely additional Italian requirement, as per the IVASS consultation, as well as
- a glossary, the terms and conditions and an application or policy form.
For the purposes of IDD transposition, Consob will launch a further consultation on the amendments to rules of conduct concerning insurance based investment products, that are currently subject to MiFID II rules in Italy, at least as far as distributed by banks or investment firms or directly by insurers.