The European Commission implementing regulation ((EU) 2017/1469) on the format and content of the Insurance Product Information Document (IPID) was published in the Official Journal of the European Union on 12 August 2017. The IPID is a requirement under the Insurance Distribution Directive ((EU) 2016/97) (IDD). As a regulation, (EU) 2017/1469 will have direct effect in the UK until Brexit.
The IDD requires that in order to make an informed decision about an insurance product before purchasing the customer should be given information in a standardised format. Responsibility for producing the IPID lies with the manufacturer of the insurance produce as determined by the IDD. The implementing regulation provides the details of what this document should look like. In particular:
- it should generally not exceed 2 sides of A4 (and never more than 3);
- the content, structure and layout of the IPID should be in a standardised format;
- the IPID should be written in plain language;
- the content should cover: ‘What is this type of insurance?’, ‘What is insured?’, ‘What is not insured?’, Are there any restrictions on cover?’, ‘Are there any restrictions on cover?’, ‘Where am I covered?’, ‘What are my obligations?’, ‘When and how do I pay?’, ‘When does the cover start and end?’ and ‘How do I cancel the contract?’; and,
- certain pre-determined symbols should be used with each section – for example, ‘What is insured?’ should be accompanied by a green tick; ‘Are there any restrictions on cover?’ should be accompanied by an orange exclamation mark; main risks included by an umbrella symbol (green on a white background or vice versa).
The IPID will need to be used from February 2018. Firms should therefore begin to put in place processes to summarise their products within the constrictions of the IPID template.
In the second Financial Conduct Authority (FCA) consultation on the implementation of IDD (CP17/23), the FCA set out proposals for how the IPID would be used alongside existing customer information requirements for example, information relating to payment protection insurance and Guaranteed Asset Protection (GAP) products.