Regulatory Alerts2024-06-26 | Circular 03/2021 (VA) – Guidance on Genuine Group Insurance ContractsGuidance on Genuine Group Insurance Contracts
BaFin issued this circular to standardize collective consumer protection for genuine group insurance contracts by establishing binding supervisory expectations for their contractual design. The guidance requires insurers to grant insured persons a direct right of action, exclude premium offsetting upon proof of payment, and ensure transparent information disclosure regarding enrolment, policy modifications, and termination options. Insurers must align existing contracts with these principles within one year of publication, while new contract designs will be evaluated against the updated standards following a six-month transitional period.
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