If your startup sells, compares or integrates insurance in its product, the question is not whether rules apply, but which regulatory status fits you: insurance company, underwriting agency, broker, agent or ancillary insurance intermediary. We analyze your model, choose the status and handle the authorization or registration with the DGSFP.
Which license or registration does your insurtech need? Free assessment
Tell us what your platform does with insurance and we will tell you which license or registration applies to you.
An insurtech can be an insurer, underwrite on behalf of others, distribute insurance or simply provide technology. Each option has different requirements, costs and timelines: we help you choose and execute.
We analyze whether you advise on, propose, conclude or compare insurance (and the customer can buy) or whether you only provide data or technology, which may fall outside the rules.
We compare insurance company, underwriting agency, broker, agent or ancillary intermediary based on your model, your partners and your growth plan.
We prepare the application for authorization or for entry in the register of distributors, with the program of activities and the documentation on the individuals involved.
If you compare or offer insurance through a website or app, we draft the written transparency policies and the information your website must display.
If you design insurance products, we define the approval process, the target market and the distribution strategy.
If your project is innovative and does not yet fit, we assess whether to submit it to the controlled testing environment, where the DGSFP is one of the authorities.
The same technology may require different statuses depending on what it does with the insurance.
Providing information based on the customer’s criteria or ranking products, when the customer can buy through your website, is insurance distribution.
If your main activity is something else and the insurance complements the good or service you sell, you may be an ancillary insurance intermediary, or be excluded if you meet the thresholds.
If you want to accept risks and set terms on behalf of an insurer, the status is that of an underwriting agency, with DGSFP authorization.
Assuming risk requires authorization as an insurance company, with the capital, solvency and governance requirements of Solvency II.
Figures from Royal Decree-law 3/2020, whose Book II governs the distribution of private insurance and reinsurance, and from the DGSFP Resolution of April 19, 2024.
Comparing or ranking insurance on a website, when the customer can buy, is insurance distribution.
An ancillary intermediary falls outside Title I if the pro-rated annual premium does not exceed €600 or, for services of up to three months, €200 per person, among other conditions.
Intermediaries and ancillary intermediaries must be entered in the register of distributors before starting the activity.
Minimum financial capacity: 4% of the annual premiums received, and never below this amount.
Minimum cover per claim under brokers’ liability insurance, with €2,315,610 per year, since October 9, 2024.
Distributing without being registered is a very serious infringement: the fine for a legal entity can reach 3% of its annual turnover or one million euros, whichever is greater.
We analyze your model and propose the most efficient status to launch, with a realistic plan for authorization or registration.
It depends on what it does. If it assumes risk, it needs authorization as an insurance company; if it underwrites on behalf of an insurer, as an underwriting agency; if it distributes insurance, it must be entered in the register as an intermediary (agent, broker or ancillary intermediary). If it only provides technology or data, without helping to conclude the contract, it may fall outside the rules.
Yes, when it provides information on insurance contracts based on the customer’s criteria, ranks products with prices and comparisons or offers discounts, and the customer can buy directly or indirectly through the website or by other means (Article 129(1) of Royal Decree-law 3/2020).
Intermediaries that use websites to offer or compare insurance must have written transparency policies and prominently publish, among other things, the selection and comparison criteria, the insurers they work with, whether their relationship with them is remunerated, whether the final price is guaranteed and how often they update the information.
Someone who, in exchange for remuneration, distributes insurance on an ancillary basis: their main activity is something else, they only distribute insurance that complements a good or service, and that insurance does not cover life or civil liability, unless it complements the good or service they sell. This is the usual status for embedded insurance.
When the insurance complements the supplier’s good or service and covers its breakdown, loss, damage or non-use, or risks of the trip booked, and the pro-rated annual premium does not exceed €600 or, if the service lasts three months or less, €200 per person. Even so, the insurer, or the intermediary on whose behalf it acts, must ensure that certain information obligations are met.
No. The status of insurance agent and that of insurance broker are incompatible for the same individual or legal entity. The broker offers independent advice, and the agent acts on behalf of the insurers it has a contract with.
Yes. Law 7/2020 created the controlled testing environment for financial innovation projects, and the DGSFP is one of its supervisory authorities. Applications are filed at the offices of the General Secretariat of the Treasury in semiannual calls; the twelfth call: September 1 to October 13, 2026.
It is a very serious infringement. For a legal entity, the fine can reach 3% of its annual turnover or €1 million, whichever is greater, among other penalties.
The right status depends on what your product does with the insurance, not on how your investor deck describes it.
Do you assume risk, underwrite on behalf of someone else, advise, compare or just provide technology? The answer defines the status.
The status you choose today shapes your partners, your revenue and your expansion. It is worth thinking about the model two or three years ahead.
Websites with clear information, written policies and product governance: the DGSFP has placed technology-based models among its supervisory priorities.
Sources: Royal Decree-law 3/2020 (Arts. 128–135, 157, 185, 192 and 194), Law 20/2015 (Art. 60) and Law 7/2020 (Arts. 3 and 6).
These terms appear in any regulatory analysis of a digital insurance project.
Advising on, proposing, concluding or assisting with insurance contracts, including comparison websites where the customer can buy.
The European directive on insurance distribution, transposed by Royal Decree-law 3/2020.
Distributes insurance that complements the good or service that is its main activity.
An intermediary that provides independent advice based on an objective analysis of the market.
An intermediary that distributes insurance on behalf of one or more insurers with which it has an agency contract.
A company that underwrites risks in the name and on behalf of insurers, with DGSFP authorization.
A product approval process with a defined target market, required of whoever designs the products.
An administrative register of the DGSFP, or of the autonomous community, in which intermediaries are entered before they operate.
A regime for testing innovative projects under supervision, including in insurance.
Broker: insurance distribution.
Ancillary intermediary: something else: the insurance complements its good or service.
Broker: any class of insurance, with independent advice.
Ancillary intermediary: only ancillary insurance; no life or civil liability cover, unless it complements its product.
Broker: entry in the register of distributors.
Ancillary intermediary: entry, unless the exclusion requirements are met.
Broker: minimum financial capacity of €23,480 and liability cover of €1,564,610 per claim.
Ancillary intermediary: outside Title I if it meets the €600 or €200 exclusion.
Broker: a platform that advises on and compares insurance across insurers.
Ancillary intermediary: e-commerce, mobility or travel businesses that add insurance to their product.
These are decisions that force you to rebuild the model or halt the launch.
Tell us what your platform does with insurance and which insurers you work with, and we will tell you which status applies to you.
Insurtech firms combine technology and insurance, but the regulation does not look at the technology, it looks at the activity. Assuming risk, underwriting on behalf of an insurer or distributing insurance are activities regulated by Law 20/2015 (LOSSEAR) and by Book II of Royal Decree-law 3/2020, which transposes Directive (EU) 2016/97 on insurance distribution.
Article 129 of Royal Decree-law 3/2020 treats as distribution any activity of advising on, proposing or doing preparatory work for the conclusion of an insurance contract, concluding it, or assisting in its management and performance, including assistance with claims. It is also distribution to provide information based on the customer’s criteria through a website, rank products with prices and comparisons or offer discounts, when the customer can buy directly or indirectly. Excluded, among others, are information that is incidental to another professional activity and the mere supply of data or information.
An insurtech can be an insurance company, with authorization and Solvency II requirements; an underwriting agency, authorized by the DGSFP to underwrite on behalf of insurers; an insurance broker or an agent, both entered in the register of distributors; or an ancillary insurance intermediary, the embedded insurance status. Each has its own rules on distribution.
Intermediaries that compare or offer insurance online must have written transparency policies and prominently publish their comparison criteria, the insurers they work with, their remuneration, whether the price is guaranteed and how often the information is updated. Embedded insurance may fall outside Title I if it complements the good or service, covers certain risks and the premium does not exceed €600 a year or €200 per person for services of up to three months.
Whoever designs insurance products must have an approval process with a defined target market. The DGSFP has included in its supervisory priorities for 2026–2028 the monitoring of technology-based proposals and product governance. For innovative projects, the regulatory sandbox under Law 7/2020 allows testing under supervision, with the DGSFP as the competent authority for insurance.
Key legislation, linked to the official text:
Legislation and links reviewed in .