Licence requirement for some group insurance providers outside the financial sector

Insurance intermediary as of 1 October 2025

Group insurance refers to an insurance contract between a policyholder and an insurer. In this example, the policyholder is a transport company. The transport company can subscribe multiple persons or companies to the policy as an insured party. A person or company can automatically join a group insurance policy, or join on a non-automatic basis. In the latter case, involving an informed decision and remuneration by the customer, the transport company will be subject to a licence requirement as of 1 October 2025. As a result of a judgment of the Court of Justice of the European Union, the transport company will, as of 1 October 2025, be regarded as an ‘insurance intermediary’.

Exceptions to the licence requirement

The licence requirement is not always relevant. You do not need a licence if your customers (the insured parties) are automatically covered by the group insurance and have no option in this matter. Nor does a licence requirement apply if there is no remuneration for the policyholder. If the aforementioned applies to you, you are exempt from the licence requirement. Additionally, there is also an ‘exemption regulation’.

More information

Webpage: Licence requirement in respect of group insurance
Interpretation group insurance (pdf, 164 kB)
judgment of the Court of Justice of the European Union