Entrepreneur
The founder setting up a brokerage
“I want to compare insurers and recommend the best on the market to my clients. I need to know what registration as a broker requires and how I prove the independence my brand promises.”
Insurance Distribution in Spain (IDD): Intermediaries and Requirements
Tied agent, linked agent, bancassurance operator or broker: we help you choose the right role and comply with the IDD and Royal Decree-law 3/2020 with evidence that stands up to an inspection.
Planning to distribute insurance? Free assessment of the right role
Tell us about your distribution model and we will tell you which role fits, which registration you need and which obligations you take on.
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Services
IDD compliance from start to finish
From choosing your role to the conflicts manual: the six pieces that turn your distribution channel into an operation you can defend.
Flagship role
Registering as an insurance broker
A broker advises independently of insurers, on the basis of an objective analysis of the market. We prepare your entry in the administrative register, the corporate structure and the policies that uphold that independence day to day.
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Royal Decree-law 3/2020IndependenceRegisterObjective analysis
Sensitive product
Distribution of IBIPs and unit-linked products
When the insurance contains an investment, the IDD raises the bar: MiFID-like customer assessments, the PRIIPs KID and enhanced cost disclosure. We set up that regime for your distribution network.
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IBIPsPRIIPs KIDSuitabilityCosts
POG
Product governance
Target market, distribution channel and periodic review: the insurance product governance that the IDD requires of manufacturers and distributors.
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Target marketReview
Conflicts
Conflicts of interest management
Commissions, corporate ties and network incentives: we identify the conflicts in your channel and design the register and the management measures.
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RegisterIncentives
Insurers
Solvency II for your insurance company
If you manufacture the product as well as distribute it, your framework is twofold: the IDD in the channel and Solvency II in the company. We cover both fronts.
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Three pillarsORSA
Customer
Insurance customer protection
IPID delivered on time, informed sales and traceable recommendations: policyholder protection as evidence, not as a slogan.
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IPID (DIP)Traceability
Profiles
Who asks us about the IDD
Four real situations that reach our firm: in all of them, the first decision is the distributor role.
Insurtech
The comparison site that sells policies
“Our website no longer just compares: we close the purchase online. That makes us distributors, and someone has to tell us which role, which training and which documents we hand over.”
Financial institution
The bank running bancassurance
“We distribute insurance through our branch network as a bancassurance operator. The question is not the role; it is proving training, product governance and conflicts management across the whole workforce.”
Agent
The agent who wants to diversify
“I am a tied agent and several insurers are offering to work with me. Switching to linked agent or jumping to broker changes my entire regime: contracts, registration and duties to the customer.”
Before you sell a policy
Three mistakes that ruin a distribution channel
Most sanction proceedings and complaints in insurance distribution stem from avoidable mistakes in channel design.
Distributing without registration: insurance mediation is an activity reserved to roles entered in the administrative register. Operating outside it exposes you to sanctions and leaves the intermediated transactions without cover.
Calling yourself a broker when you are not one: presenting yourself as independent while being paid by a single insurer, with no objective market analysis, misleads the customer and the supervisor at the same time.
Selling IBIPs as simple insurance: placing a unit-linked product without assessing the customer or delivering the PRIIPs KID shifts onto the distributor a complaint risk that no commission can make up for.
| Role | Dependence on the insurer | Which model it suits |
|---|---|---|
| Tied agent (agente exclusivo) | Total: works for a single insurer, which is liable for its conduct. | Captive sales networks and newcomers starting out with the full backing of one insurer. |
| Linked agent (agente vinculado) / bancassurance operator (operador de banca-seguros) | Partial: works with several insurers under agency agreements; the operator channels the network of a credit institution. | Multi-insurer distribution without full independence, and insurance sales through bank networks. |
| Broker (corredor) | None: independent, advises on the basis of an objective market analysis. | Those who build their value proposition on impartial recommendations to the customer. |
Set up your distribution channel without surprises
We analyze your model, choose the role with you (agent, bancassurance operator or broker), handle the registration and get training, the IPID, product governance and conflicts of interest up and running. All backed by evidence.
Frequently asked questions
IDD and insurance distribution: common questions
What is the IDD and how does it apply in Spain?
The IDD (Directive (EU) 2016/97) is the EU law that regulates insurance distribution: who may distribute, with what training, what information the customer receives and how conflicts of interest are managed.
In Spain it is transposed by Royal Decree-law 3/2020 (Real Decreto-ley 3/2020), which sets out the distributor roles (tied agent, linked agent, bancassurance operator and broker) and their obligations toward the customer and the supervisor.
What is the difference between an agent and a broker?
Dependence. An agent acts on behalf of one or more insurers under agency agreements: tied if it works for just one, linked if it works for several. A broker, by contrast, is independent of insurers and must advise on the basis of an objective analysis of a sufficient number of contracts available on the market.
That independence is not a title: you must be able to prove it in practice, from your revenue structure to the comparison behind each recommendation. We cover it on our insurance broker license page.
What is a bancassurance operator?
It is the role designed for credit institutions to distribute insurance through their networks. The bancassurance operator acts as an agent (tied or linked, depending on whether it works with one or several insurers) and channels the activity of the institution’s branch network.
Its compliance challenge is one of scale: proving the training of the whole network involved in sales, controlling the conflicts of interest specific to the banking channel and documenting that each policy was offered with the IPID and the assessments the product requires.
Do I need to register anywhere to distribute insurance?
Yes. As a general rule, insurance distribution requires prior entry in the administrative register of distributors, under the terms of Royal Decree-law 3/2020. Without that registration there is no lawful mediation activity.
The application varies by role: for a broker it includes, among other things, organizational, financial capacity and professional guarantee requirements under the applicable rules; for agents, much of the control rests with the insurer they contract with.
What training does the IDD require of those who sell insurance?
The IDD requires those who distribute insurance to have appropriate knowledge and ability for the products they sell, with documented initial and continuing training. In Spain, implementing regulations set different training levels according to the duties performed and the type of product.
In practice, the supervisor expects to see a documented training plan, individual records per person and content consistent with the actual product range: the same course will not do for someone who sells home insurance and someone who distributes unit-linked products.
What is the IPID (DIP) and when must it be delivered?
The insurance product information document (IPID, or DIP in Spanish) is the standardized document that summarizes, for non-life insurance, the main cover, exclusions and obligations under the policy in a short, comparable format.
It must be given to the customer before the contract is concluded, with enough time to make an informed decision. For insurance-based investment products the key pre-contractual document is a different one: the KID under the PRIIPs Regulation.
What does the IDD require on product governance?
The IDD brings to insurance a logic similar to MiFID product governance: the manufacturer (the insurer) must design each product for a defined target market, choose consistent distribution channels and periodically review whether the product still works for that market.
The distributor, in turn, must know the target market, obtain product information from the manufacturer and feed sales data back to it. We explain this in detail on our product governance page.
How are conflicts of interest managed in distribution?
The IDD requires distributors to act honestly, fairly and professionally in the best interests of the customer, and to identify and manage the conflicts of interest their model creates: commissions that reward one product over another, corporate ties with insurers, network sales campaigns.
The operational answer is a written policy, a live conflicts register and, where management is not enough, disclosure to the customer before the contract is concluded. We have a dedicated page on conflicts of interest in financial institutions.
Practical guide
From idea to a compliant distribution channel
Distributing insurance under the IDD is not a one-off formality: it takes a well-chosen role, a registration and a compliance system that works in every sale. This is how we build it.
Role and business model fit
Will you be paid by one insurer, by several or by the customer? Do you promise independence? Those answers determine the role: tied agent, linked agent, bancassurance operator or broker. Changing it later costs you contracts and registration work.
Registration and requirements
We prepare the application for entry in the administrative register according to the role: organization, good repute, documented training and, where applicable, professional guarantees under the applicable rules.
Operations backed by evidence
IPID delivered and filed, documented assessments for IBIPs, recorded continuing training, product governance with the manufacturer and a conflicts register: the day-to-day work that makes you defensible before the supervisor.
IDD checklist in 10 steps
- Distribution model: define your products, channel (in person, by phone, online), revenue sources and degree of ties with insurers.
- Choice of role: tied agent, linked agent, bancassurance operator or broker: decide based on the business model, not on the marketing label.
- Contracts with insurers: formalize agency agreements, or terms-of-business letters with brokers, consistent with the chosen role and with your independence message.
- Administrative register: prepare and file the registration application with the organizational, good repute and guarantee requirements that apply to your role.
- Team training: document initial and continuing training appropriate to the products distributed, with individual records per person.
- Pre-contractual documents: implement delivery and filing of the IPID for general insurance and of the PRIIPs KID for insurance-based investment products.
- Advised sales and IBIPs: define when you advise and when you do not, and apply the enhanced customer assessments for unit-linked and other IBIPs.
- Product governance: agree with each insurer how target market, product information and sales data are exchanged.
- Conflicts and incentives: approve the conflicts of interest policy, record the conflicts identified and review the network’s commission schemes.
- Ongoing monitoring: schedule reviews of training, documentation and customer complaints to detect channel failures before the supervisor does.
If your project is a brokerage, start with our insurance broker license service; if you distribute products with an investment component, continue with IBIPs and unit-linked products.
Working glossary
Essential insurance distribution vocabulary
These are the terms you will see in Royal Decree-law 3/2020, in contracts with insurers and in any request for information from the supervisor. It pays to use them precisely.
IDDFramework
Insurance Distribution Directive
Directive (EU) 2016/97: it regulates who distributes insurance in the EU, with what training, what pre-contractual information and what conflicts management.
Transposed in Spain by Royal Decree-law 3/2020.
Tied agentRole
A single insurer
Distributes for a single insurer under an agency agreement. The insurer takes responsibility for its conduct and for much of its oversight.
The simplest way into the sector.
Linked agentRole
Several insurers, no independence
Works with several insurers under agency agreements. It broadens the product range, but does not advise on the basis of the objective analysis that characterizes a broker.
Multi-insurer distribution without a promise of impartiality.
Bancassurance operatorRole
The banking channel
The vehicle through which credit institutions distribute insurance via their branch networks, as tied or linked agents.
Its big challenge: training and control of the network.
BrokerRole
Independence and objective analysis
A distributor independent of insurers that advises on the basis of an objective analysis of a sufficient number of contracts available on the market.
Independence is proven, not declared.
IPID / DIPDocument
Standardized product information
A short, comparable document summarizing the cover, exclusions and obligations of non-life insurance, delivered before the contract is concluded.
For IBIPs, the key document is the PRIIPs KID.
IBIPProduct
Insurance with an investment inside
An insurance-based investment product, such as a unit-linked policy: it requires MiFID-like customer assessments and a PRIIPs KID.
The IDD’s enhanced regime.
POGGovernance
Insurance product governance
The obligation to design each product for a target market, choose consistent channels and review it periodically; the distributor provides feedback to the manufacturer.
Similar to MiFID product governance.
Administrative registerAccess
The key to the activity
Mandatory prior registration of insurance distributors. Without a registration entry there is no lawful mediation, whatever the role.
The application varies depending on the role chosen.
Distributor playbook
What the supervisor expects from your channel (and how to prove it)
Role and registration
Distribution activity covered by a registered role, consistent with the actual revenue model and ties with insurers.
Registration entry, agency or brokerage agreements and a map of relationships with insurers.
Training
Knowledge and ability appropriate to the products distributed, with documented initial and continuing training.
Training plan, individual certificates and an up-to-date person–product matrix.
Pre-contractual information
IPID delivered on time for general insurance and PRIIPs KID for IBIPs, with proof of delivery.
Document repository per policy, timestamps and reviewed sales scripts.
Product governance
Distribution within the target market defined by the manufacturer, and sales information fed back to it.
Target market sheets, information-exchange agreements with insurers and minutes of periodic reviews.
Conflicts of interest
Identification and management of the channel’s conflicts, with disclosure to the customer where management is not enough.
Approved policy, live conflicts register and analysis of commission schemes.
Signs that your insurance channel has a problem
If any of these sound familiar, review the fit before an inspection or a customer complaint does it for you.
- You present yourself as an “independent broker”, but more than half of your portfolio comes from a single insurer and you do not document any objective analysis.
- Your website closes sales online and nobody has analyzed whether that makes you a distributor subject to registration.
- You sell unit-linked products with the same script and the same paperwork as home insurance.
- You cannot prove what training each person involved in sales has, or when they renewed it.
- Your network’s commissions reward a specific product and nobody has checked this against the conflicts policy.
Related framework
Insurance distribution does not stand alone: look at the rest of the board
The IDD is one piece of a larger framework: investment-linked products have their own enhanced regime, insurers answer to Solvency II, and the product and conflicts rules draw on the MiFID world. These pages complete the map of your distribution channel.
Product
IBIPs and unit-linked products
The IDD’s enhanced regime for investment-linked insurance: customer assessments, the KID and the boundary with funds.
See the regime →
IBIPsKID
Prudential
Solvency II
The prudential framework for insurers: three pillars, key functions and ORSA. Essential if you manufacture products.
See Solvency II →
SCR/MCRORSA
POG
Product governance
Target market, channels and periodic review: the product discipline shared by MiFID II and the IDD.
See the discipline →
Target marketChannels
Conduct
Conflicts of interest
How to identify, record and manage the conflicts in a financial distribution channel without slowing down the business.
See the policy →
RegisterManagement
If your project is to open a brokerage, start with registering as an insurance broker. And if your channel sits alongside investment services, review the suitability test, financial consumer protection and our financial compliance service.
Contact
Book a call
Tell us how you want to distribute insurance (channel, products, ties with insurers) and we will map out the full regulatory path for you.
Insurance distribution under the IDD: roles, registration and obligations
Directive (EU) 2016/97 (IDD) sets out, across the EU, who may distribute insurance and with what duties toward the customer. In Spain it was transposed by Royal Decree-law 3/2020, which establishes the distributor roles (tied agent, linked agent, bancassurance operator and broker), prior entry in the administrative register, the training requirements, pre-contractual information (with the IPID as the centerpiece for general insurance), product governance and conflicts of interest management. Choosing a role is the first strategic decision: it shapes your revenue, contracts, registration and the sales message you will be able to sustain.
Distributor roles: from exclusivity to independence
The tied agent distributes for a single insurer, which is liable for its conduct; the linked agent works with several insurers under agency agreements; the bancassurance operator channels distribution by credit institutions through their networks; and the broker is independent of insurers and advises on the basis of an objective market analysis. The decisive boundary is independence: only a broker can build its offering on impartiality, and in return it takes on its own organizational and guarantee requirements. We analyze this role in detail on our insurance broker license page.
Registration, training and customer information
As a general rule, distribution requires prior entry in the administrative register of distributors, with an application that varies by role. On top of that, everyone involved in sales must be able to prove initial and continuing training appropriate to the products distributed, and standardized information must be delivered before the contract: the IPID for non-life insurance and the KID under the PRIIPs Regulation for insurance-based investment products. None of this counts without traceability: the supervisor does not ask whether you informed the customer; it asks how you prove it.
Product governance and conflicts: the conduct behind the sale
The IDD includes product governance rules similar to those of MiFID II: the manufacturing insurer defines a target market, selects consistent channels and periodically reviews the product; the distributor sells within that market and feeds sales information back. At the same time, the distributor must act in the customer’s best interests and manage the conflicts of interest in its model: asymmetric commissions, ties with insurers, campaign incentives. We have dedicated pages on both areas: product governance and conflicts of interest.
The step up: insurance-based investment products
When the insurance includes an investment component (unit-linked being the typical case), the IDD triggers an enhanced regime with MiFID-like customer assessments and specific documentation. We cover that ground, where insurance and securities markets meet, on our IBIPs and unit-linked products page. And if you manufacture products as well as distribute them, your company also answers to the prudential framework of Solvency II: two different regimes that must tell the same story.
Insurance and products
Conduct and compliance
Official sources
Key legislation, linked to the official text:
- Directive (EU) 2016/97 of January 20, 2016 on insurance distributionEUR-Lex · Official Journal of the EU
- Royal Decree-law 3/2020 of February 4 on urgent measures transposing various European Union directives into Spanish lawBOE · consolidated text
Legislation and links reviewed in .