Update on “Value for Money” concerns in the life insurance sector – Outcome of the CAA Quantitative Questionnaire

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On 7 March 2023, the Commissariat Aux Assurances (“CAA”) published Information Note 23/4 on the results of the quantitative “Value for Money” questionnaire (“Information Note 23/4”).

1. Background

During the last quarter of 2022, the CAA asked life insurance undertakings to complete a questionnaire including information about the reductions in returns (“réductions de rendements”) that life insurance undertakings observed for their main products compared to the reductions in returns indicated in their key information document (“KID”) issued in accordance with Regulation 1286/2014 on key information documents for packaged retail and insurance-based investment products (“PRIIPs”).

Information Note 23/4 should be read together with the recent initiatives undertaken by the European Insurance and Occupational Pensions Authority (“EIOPA”) in relation to value for money concerns regarding unit-linked insurance products. These include in particular:




These EIOPA initiatives are closely linked to the product oversight and governance requirements imposed under amended Directive 2016/97 on insurance distribution (“IDD”) and Commission Delegated Regulation 2017/2358 supplementing IDD with regard to product oversight and governance requirements for insurance undertakings and insurance distributors.


2. Key findings

The key findings of Information Note 23/4 differ depending on the nature of the relevant insurance products:



However, the CAA also notes that retail clients are heavily penalised on premature exits, notably because of surrender penalties.



Read the Information Note (French Only) here ­_

Read the EIOPA Supervisory Statement here ­_

Read the EIOPA Methodology here ­_


If you require any assistance or advice regarding “Value for Money” concerns, particularly the review of the product oversight and governance process or the KID, please contact our insurance experts.

Download the press release

Luxembourg Newsflash – Update on “Value for Money” concerns in the life insurance sector

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