Thursday, 16 April 2026
The Polish Financial Supervision Authority has released an updated draft of its recommendations for insurance distribution, introducing a number of changes to proposals first consulted in 2025. The revised version reflects feedback from market participants and is intended to replace the regulator’s existing 2014 guidelines.
The draft aims to align supervisory expectations with current legislation, including the Act on Insurance Distribution and the Solvency II framework. Although comments were invited until the end of March 2026, the regulator expects the final recommendations to take effect from January 2027, with some investment-related provisions deferred until mid-2028.
A central element of the revised draft remains the concept of product value. Insurers are expected to ensure that products provide appropriate value to customers, measured in part by the relationship between expected benefits and premiums. The guidance sets minimum thresholds, including lower requirements for low-premium products. Compared to earlier rules, this approach is now extended across a broader range of products and distribution channels, while maintaining certain exclusions such as large-risk coverage and selected pension products.
For life insurance products that include a savings component, the draft introduces a separate test limiting the annual cost impact.
In the area of remuneration, the regulator steps back from earlier proposals for more prescriptive structures. Insurers are still expected to maintain internal policies governing pay and incentives for employees and intermediaries, but the focus shifts to ensuring that remuneration does not conflict with the obligation to act in the customer’s best interest. The use of qualitative indicators, such as complaints or customer satisfaction, is recognised as part of remuneration frameworks.
The revised draft also adjusts expectations around cooperation with agents. While insurers remain responsible for oversight, the emphasis is placed on monitoring compliance, providing support and taking corrective measures where needed. More detailed requirements regarding the verification of relationships between agents and sub-agents have been removed, with greater reliance placed on proportionality.
Changes are also visible in how insurers assess customer needs. The updated draft adopts a more flexible approach, removing earlier proposals that could have prevented policy conclusion if a client declined to complete questionnaires. For renewals, insurers may rely on previously collected information, provided customers are informed and able to update their data.
In relation to brokers, the regulator no longer proposes restrictions on performance-based remuneration. Instead, the focus is on maintaining independence and managing conflicts of interest, signalling a less interventionist approach to contractual arrangements.
The recommendations are expected to operate on a “comply or explain” basis, requiring insurers that diverge from the guidance to justify their approach to the regulator. Market participants, including domestic insurers, branches of foreign companies and EU-based firms operating in Poland, are expected to assess the potential impact of the proposals on product design, distribution processes and internal governance ahead of their formal introduction.
Source: CMS
