The Dutch Authority for the Financial Markets published guidance on “embedded insurance”, setting out legal requirements and recommendations for insurers, intermediaries and platforms to safeguard customer interests when insurance is sold as part of the purchase process for another product or service. The AFM notes that embedded insurance is increasingly offered both in physical and online sales journeys and via a wide range of platforms, from small webshops to large (neo)banks integrating insurance into paid subscription services, including on websites of non-insurers. While embedded insurance can add convenience and help prevent uninsured losses, the AFM highlights risks that customers make less well-considered choices and face overinsurance or underinsurance, and points to earlier observations that embedded products may differ from traditional insurance in coverage and term. The guidance covers, among other topics, licensing obligations, product development standards, information disclosure requirements and expectations around ongoing service for insurance products.
Dutch Authority for the Financial Markets 2025-11-24
Dutch Authority for the Financial Markets issues guidance on safeguarding customer interests in embedded insurance
The Dutch Authority for the Financial Markets issued guidance on embedded insurance, detailing legal requirements and recommendations for insurers, intermediaries, and platforms to protect customer interests. It addresses risks like overinsurance and underinsurance, covering licensing, product development, information disclosure, and ongoing service expectations. The AFM highlights the growing prevalence of embedded insurance in physical and online sales, noting potential differences from traditional insurance products.