The Dutch Authority for the Financial Markets (AFM) has published guidance warning that companies which offer “group insurance” to their customers alongside their main business activity may need to be authorised as an insurance intermediary from 1 October 2025, following clarification from a Court of Justice of the European Union ruling. The AFM describes a group insurance arrangement as a policy taken out by an insurer with a company such as a transport or removals firm, where the company is the policyholder and can add customers (individuals or businesses) as insured persons. Where customers make a deliberate choice to be insured under the group policy and the company receives a fee for this, the company will be treated as an insurance intermediary and will need to apply for an AFM licence. The AFM notes exceptions where customers are automatically covered with no choice, or where no remuneration is charged, and references an additional exemption regime and a factsheet to help firms assess whether authorisation is required. With the authorisation requirement applying from 1 October 2025, the AFM indicates there is roughly four months to submit an application, noting that its licensing process typically takes at least 13 weeks and recommending that firms apply well in advance.
Dutch Authority for the Financial Markets 2025-02-28
Dutch Authority for the Financial Markets clarifies that firms offering group insurance may need an insurance intermediation licence from 1 October 2025
The Dutch Authority for the Financial Markets (AFM) has issued guidance that companies offering "group insurance" alongside their main business may need to be authorised as insurance intermediaries by 1 October 2025, following a Court of Justice of the European Union ruling. Companies will require an AFM licence if they receive fees for allowing customers to opt into group policies. Exceptions apply where customers are automatically covered without choice or remuneration.