CNPF Proposes a New Framework for Insurance Distribution: Greater Transparency, Clear Rules for Intermediaries, and Enhanced Client Protection

The National Commission for Financial Markets (CNPF) has developed a new regulatory framework for insurance distribution, and on May 5, 2026, the CNPF Board of Directors approved the transmission of the draft law to the Ministry of Finance for promotion.

The draft law aims to modernize the framework applicable to the distribution of insurance and reinsurance products by aligning national legislation with Directive (EU) 2016/97 on insurance distribution. Through the promotion of this draft, the goal is to create a modern conduct framework for the insurance market, where client protection, transparency, professional responsibility, and the prevention of conflicts of interest become central elements of distribution activities.

A novel element is the diversification of channels through which insurance policies can be contracted. The draft more clearly regulates the roles of insurance companies, brokers, insurance agents, bancassurance agents, brokerage assistants, and auxiliary intermediaries. This approach can contribute to increased competition in certain market segments and, consequently, to the optimization of costs for certain categories of insurance products.

Furthermore, the draft establishes uniform requirements regarding the professional knowledge and competencies of persons involved in insurance distribution, regardless of the type of insurance distributor, to ensure that clients receive an appropriate level of information and advice during the insurance policy contracting process.

Another important element is the strengthening of pre-contractual information requirements. Insurance distributors will be required to provide clients with clear information regarding the proposed product, the capacity in which they act, the method of remuneration, the existence of any potential conflicts of interest, complaint submission procedures, and out-of-court dispute resolution mechanisms.

Additionally, the draft introduces rules regarding the assessment of client requirements and needs, so that the proposed insurance contract is suitable for the client's profile and interests. Where advice is provided, the distributor must present a personalized recommendation and explain why a specific insurance product best meets the client's needs.

Regarding insurance companies and intermediaries that create insurance products, the draft establishes requirements concerning the approval, review, and distribution process of products. This process must be proportional to the nature of the insurance product and identify the target market.

Regarding insurance-based investment products, the draft provides additional client protection requirements. The distributor must collect information regarding the client's knowledge and experience, financial situation, ability to bear losses, investment objectives, and risk tolerance, so that the proposed product is suitable for the client's profile.

To align with the European Union internal market, the draft establishes rules regarding the exercise of the freedom of establishment and the freedom to provide services, as well as cooperation and information exchange mechanisms between competent authorities.

The draft law on insurance distribution will be promoted by the Ministry of Finance and will subsequently be subject to advisory and public consultation procedures.

Decisions of the Board of Directors of the National Commission for Financial Markets – April 28-29, 2026

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