Do you want an insurance for that? - Online steering towards embedded insurance

ANALYSIS REPORT 'Do you want an insurance for that?' – online steering towards embedded insurance

In brief – The AFM has investigated how insurance is offered online during the purchase of other products and services, such as a bicycle or holiday. Our exploration shows that the online choice environment of platforms with 'embedded insurance' often contains multiple elements that strongly steer consumers towards purchasing insurance during the purchase decision, including unbalanced presentation of options, low-threshold enrollment, and incentives such as social influence. Information provision is often limited in this regard. This degree of steering does not appear to be proportional to the extent to which these products are actually suitable for consumers. The AFM emphasizes the importance of a careful design of the choice environment.

JULY | 2026

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Summary The AFM has conducted an exploration of the online choice environment of platforms offering embedded insurance. Embedded insurance refers to insurance offered without advice (execution only) during the purchase of another product or service, often on (online) non-financial platforms. These insurance products logically often have coverage that is strongly related to the product or service with which they are purchased, meaning they can overlap with other insurance policies consumers already have, leading to over-insurance. With this publication, we follow up on our November 2025 research regarding the opportunities and risks of embedded insurance.

In this research, the AFM explores the presence of steering elements on platforms offering embedded insurance and their possible consequences for suitable choices by consumers. For this exploration, 22 online choice environments were observed in which insurance is offered as an additional product during the purchase of a product or service. In each case, the entire customer journey of the product or service was followed – from the orientation phase to the moment of checkout – to identify the presence of elements that could steer behavior.

This exploration reveals that embedded insurance on platforms is often prominently and repeatedly brought to attention and can be concluded with low thresholds.

Insurance products are offered at multiple moments in the purchase process and presented as an additional service or protection for the main product. The choice between insuring and not insuring is designed unevenly on many platforms: insurance options are visually and textually highlighted, while the option not to insure is less visible or requires more actions. This manner of offering can strongly direct consumer attention to the insurance option and potentially influence the perceived necessity of the product.

Information provision regarding embedded insurance is layered, with information in the top layer being limited and underlying information often complex and difficult to access. On the main page, the emphasis is primarily on positive elements of the coverage, while important aspects such as limitations, duration, terms and conditions, cost structure, and possible overlap with existing insurance are often insufficiently explained. This creates the risk that consumers make choices based on an incomplete and one-sided image.

Furthermore, many platforms use various textual, visual, and social influence mechanisms that can contribute to choice pressure. Examples include emphasizing security and protection, using social proof such as 'most chosen', striking colors and positive icons when presenting the insurance, and the presence of time pressure during the purchase process. These elements can prompt consumers to make quick decisions and steer them towards concluding the insurance.

The AFM concludes that the current design of many choice environments carries the risk that consumers conclude an insurance that is not suitable for their situation or preferences. The combination of low-threshold enrollment, limited and difficult-to-access information, and the combination of multiple steering elements can lead to consumers being insufficiently able to make a well-considered decision. The AFM therefore emphasizes the importance of a careful design of the choice environment, so that consumer interest is better safeguarded when offering embedded insurance.

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Although the AFM did not look into violations of legal requirements in this exploration, the design of the choice environment can cause providers and/or platforms to fail to meet legal standards on which the AFM can enforce. Regarding the design of the choice environment, the AFM emphasizes that it must, among other things, comply with legal standards for information provision, product development, and unfair commercial practices.

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Table of Contents

1. Introduction 5
2. Observations 8 2.1 Choice Structure: How is the insurance offered? 8 2.2 Choice Information: What information does the consumer receive? 11 2.3 Choice Pressure: What incentives are added? 14
3. Conclusion 17
4. References 19

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1. Introduction Insurance is increasingly being offered during the sale of other types of products or services by (online) non-financial platforms or shops. Think of an insurance that appears as an additional choice when purchasing a flight ticket, festival ticket, or television. This is also known as embedded insurance. In 2025, 1 in 8 consumers stated that they had concluded an insurance during the past year when purchasing another product or service (AFM, 2025a). In 6 out of 10 cases, this happened online. This usually concerned a cancellation insurance, for example for a flight ticket or concert ticket, but also often theft, warranty, or travel insurance (AFM, 2025a).

Embedded insurance differs in several ways from insurance that consumers can independently conclude online via the insurer or a comparison website.

1 Consumers who conclude insurance directly with the insurer or on a comparison website are often explicitly looking for an insurance. Consumers can take the time to compare providers, terms, and prices side by side. With embedded insurance, this possibility is more limited. This is because these are often product- or service-specific and therefore harder or impossible to compare with alternatives. With embedded insurance, the insurance is offered as part of another product or service, integrated into the purchase process and often amidst many other 'extras'.

As a result, consumers will likely take less time or have fewer opportunities to evaluate the product.

Due to the expected growth of embedded insurance, the AFM focused in recent research on the opportunities and risks of embedded insurance (AFM, 2025b). In that research, we noted that this form of insurance distribution can help consumers avoid uninsured damage. This is partly because these insurance products are brought to attention in an accessible manner in combination with a relevant product or service to be insured. At the same time, the low-threshold nature of this distribution method also brings an increased risk of unsuitable insurance; partly because the consumer's attention during the purchase is primarily focused on the main product (AFM, 2025b). This can lead to consumers being over-insured, for example because they conclude an insurance that (partially) covers the same risk as an insurance they already have. We also see a risk of under-insurance, where consumers think they are sufficiently insured, while the embedded insurance only offers a limited or superficial coverage level. Besides mentioning opportunities and risks, the AFM also explained the most important regulations for providers and platforms in this report. Additionally, we made recommendations to safeguard consumer interest when offering embedded insurance. These include, among other things, the importance of a careful design of the online choice environment. The most important characteristics of the embedded insurance market are stated in the box below.

1 Consumers can also conclude insurance via an advisor. This form of distribution falls outside the scope of this research.

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The market for embedded insurance. Embedded insurance is a digitally driven market in which insurance is integrated into the purchase process of products and services, often via online platforms outside the traditional financial sector.

The market consists partly of an international and fragmented value chain.

Providers, such as insurers and authorized agents, regularly operate from an EU member state outside the Netherlands, while platforms, ranging from small (web)shops to large (neo)banks, function as the customer contact point. This increases the scale and growth potential of the market, but also makes the structure and supervision of the market more complex.

Data about the consumer is shared for integrating embedded insurance into a platform.

Here, qualitatively good data and technology are of primary importance to ensure that the offer aligns with the consumer's needs and that the consumer can easily conclude the product.

Platforms often distribute this insurance without having an AFM license.

For this, they make use of exceptions or exemptions from the licensing requirement. This creates a hybrid distribution model, where responsibilities for compliance with laws and regulations are divided between the provider and the platform.

The AFM sees the risk that concluding an embedded insurance is not suitable for the consumer in all cases. Embedded insurance logically often has coverage that is strongly related to the product or service with which it is purchased. These coverages can overlap with other insurance policies consumers already have, leading to over-insurance. For example, consumer research shows that 78% of consumers have a household contents insurance, with a significant chance that the coverage from this insurance overlaps with, for example, a warranty insurance (AFM, 2025a). In other cases as well, it is questionable whether concluding an embedded insurance is suitable for consumers, for example if they already have rights to another form of guarantee or can receive restitution in another way. Precisely for this reason, it is important that embedded insurance is offered in a careful manner, providing sufficient information so that the consumer can assess whether the insurance is suitable for them.

For many consumers, the choice to conclude an insurance is a complex weighing of options, causing them to often fall back on simplified decision rules, emotions, and intuition (Sydnor, 2010; Ranyard et al., 2017). Choosing an insurance requires a complicated assessment of the probability of a risk occurring, the possible financial consequences, and the extent to which an insurance provides protection against this. When making such complex choices, consumers often fall back on heuristics, emotions, and intuition, rather than making a systematic weighing of all relevant information (AFM, 2021; Ranyard et al., 2017).

The way platforms design the online choice environment when offering insurance can therefore have a major influence on the choices consumers make. The way websites are designed determines to a large extent how consumers perceive information, process it, weigh alternatives against each other, and make choices (AFM, 2021). Design choices such as language use, order, or visual accents can therefore – intended or unintended – influence consumer choice behavior. In earlier research, the AFM therefore emphasized the importance of a careful design of the online choice environment when offering embedded insurance (AFM, 2025b).

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The design of the choice environment also touches upon a number of relevant legal standards that providers and/or platforms must adhere to. Certain information, such as the Insurance Product Information Document (IPID), must be provided mandatorily, and all information provision to consumers must be correct, clear, and not misleading. Furthermore, the design of the choice environment can be part of the distribution strategy that ensures insurance is offered to the right target group. Additionally, it is an unfair commercial practice if the design and functionality of the choice environment steer the decision-making power of consumers so much that they make a decision they would not have made otherwise. 2

For this exploration, we have highlighted the presence of steering elements in the choice environment of platforms offering embedded insurance and the associated risks for consumers. For this, the choice environments of 22 products and services were observed, where insurance is offered as an additional product. The exploration included products and services within six branches where embedded insurance is common: events and flight tickets (cancellation insurance), travel from tour operators (travel insurance), electronics (warranty insurance), mobile phones (device insurance), and rental cars (various additional insurance). This selection was made because, for the majority of consumers who stated they had concluded one or more embedded insurances in the past year, about 8 out of 10 did so within one of these branches (AFM, 2025a). Within each branch, platforms were selected that serve a significant group of consumers.

During the observations, the entire customer journey of the product or service was followed from the orientation phase to the moment of checkout. For assessing the choice environment, a pre-determined observation framework was used, filled in by two independent observers for each customer journey. This observation form is based on insights from behavioral science literature. The observations in this report are based on a snapshot in November and December 2025. Although the number of observed customer journeys provides important insights into possible risks, it does not offer a complete and representative picture of the total embedded insurance market.

Chapter 2 summarizes the most important observations and divides them into three sections: (2.1) How is the insurance offered? (2.2) What information does the consumer receive? (2.3) What other forms of influence are used? In Chapter 3, a conclusion is drawn based on the findings regarding the risks we see after our observations.

2 For financial service providers, additional specific requirements regarding the design of the choice environment apply as of June 19, 2026, with the entry into force of the DMFSD in Article 4:25, first paragraph, Wft joint Article 81.0a BGfo. Additionally, under the DMFSD, the requirements for distance selling have been tightened, with Article 230oa Book 6 BW stipulating that consumers, under certain conditions, can terminate the (insurance) contract via an easy and accessible function on the platform's website.

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2. Observations 2.1 Choice Structure: How is the insurance offered? 2.1.1 Insurance products are prominently and repeatedly brought to attention during the customer journey

On many platforms, the possibility to conclude an insurance is brought to attention in a prominent manner during the purchase process of a product or service. The amount of attention the insurance receives in the customer journey varies between platforms. On some platforms, consumers go through a full webpage (entirely dedicated to one or more insurances) to complete the purchase. Other platforms show the insurance(es) as part of a page with multiple 'extras' to be concluded. There are also platforms that highlight the insurance(es) via a frame as part of a page with other information. For example, on the product page or during the checkout phase. Depending on how these frames are designed by the various platforms, the insurances attract more or less attention.

On many of the platforms, consumers are pointed out at multiple moments to the possibility of concluding an insurance. There are differences between the observed platforms in the frequency with which insurance products are offered during the customer journey. For providers who bring the insurance to attention at multiple moments, this often begins with information on the product page, followed by a separate page entirely dedicated to the insurance, and ends with a final opportunity to add the insurance during the checkout phase.

Because insurances are offered prominently and repeatedly during the customer journey, the perceived necessity of this product can become distorted. The prominent and repeated presence of the insurances during the customer journey will increase attention for this option (Bardelo et al., 2013) and can influence consumer perception (Krijnen et al., 2017). Consumers may therefore possibly overestimate the risks and the perceived necessity of an insurance and be more inclined to conclude it.

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2.1.2 Choice to insure and not to insure is presented unevenly and there is no possibility to compare with alternatives

When making the insurance choice, the choice to insure is often shown significantly more prominently than the choice not to insure. The way the choice to insure or not is presented varies per platform. Many platforms make the option to conclude an insurance more visible than the option to decline it. They use various methods for this. The insurances are often highlighted using striking cards, color usage, or frames. While the 'no' option is not always placed alongside the insurance products on an equal footing. It is, for example, placed under the options or at the bottom of the page in a less striking design, such as in smaller or gray letters, without a colored frame. In other cases, an explicit 'no' option is completely missing. The consumer then chooses not to insure by not selecting any of the insurances and proceeding to the next step in the process. However, it is not always clear that this is the intention, and by not explicating this, consumers may possibly get the idea that there is a mandatory choice for one of the insurance products.

All platforms offer a limited number of insurances. The observed platforms all offer one to three insurance products. When multiple options are offered, they often differ in the type of insurance (for example, travel or cancellation insurance) or in the degree of coverage. Often, the options are shown in order of increasing price and coverage. On platforms that offer insurances with different coverage levels, consumers often get insight into the differences. These are, for example, textually highlighted or via a table with checkmarks and crosses, showing which elements are and are not covered. On none of the observed platforms is it made clear whether it is possible to conclude the insurance at a later moment or to conclude a comparable insurance via another provider.

Due to an uneven presentation of insuring and not insuring and the absence of comparison possibilities, consumers are steered towards the offered insurance. The uneven presentation of options can steer consumers towards concluding an insurance (Mertens et al., 2022; Orquin et al., 2021; Hilchey et al., 2023). Although the limited number of offered insurances keeps the choice set clear for the consumer, this also means that there is no (easy) comparison with alternatives possible. Embedded insurances are moreover

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often tailored to a specific product or specific service. As a result, comparing terms and prices between policies is harder than with other insurances or even completely impossible.

2.1.3 Concluding an insurance is easy and low-threshold

On almost all platforms, concluding an insurance is very easy and low-threshold. Consumers can often conclude the insurance with just one click. On many platforms, it is stated in small print, for example under the choice option or next to a checkbox, that by checking the insurance, consumers automatically agree to the general terms and conditions. Furthermore, consumers on most platforms do not need to provide additional information to enter into the insurance. This is likely using information already provided by the consumer during the purchase process of the product or service (such as personal data and payment details). Entering into the insurance is therefore a frictionless experience.

On some platforms, not insuring requires more actions than concluding an insurance. On these platforms, consumers must confirm multiple times that they do not want an insurance. For example, there are platforms where a pop-up appears offering the insurance again or asking if the consumer is sure of the choice not to insure.

The ease and low threshold of concluding can contribute to more consumers concluding an insurance and taking less time for it. In general: the easier it is for people to perform a certain task, the more likely it is that it will be completed (AFM, 2021; Mertens et al., 2022). Although this frictionlessness can offer convenience to consumers, it also brings a risk of less well-considered decisions (Zhao et al., 2022). Consumers are therefore possibly less likely to reflect on the terms of the insurance, overlap with the coverage of insurances they already have, or whether the coverage of the insurance is actually suitable. In extreme cases, this can lead to

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impulsive decisions. The low threshold also means that consumers may not realize they are concluding an insurance at all, or that they are concluding an insurance that is not suitable for them.

2.2 Choice Information: What information does the consumer receive? 2.2.1 Information provision is layered and limited

The information provided to consumers regarding embedded insurance is often limited and complex. On the main page, the emphasis is primarily on positive elements of the coverage, while important aspects such as limitations, duration, terms and conditions, cost structure, and possible overlap with existing insurance are often insufficiently explained. This creates the risk that consumers make choices based on an incomplete and one-sided image.

Information is often provided in layers. The top layer contains limited information, while underlying information is often complex and difficult to access. Consumers must often click through multiple screens or expandable sections to find detailed information about the insurance. This makes it difficult for consumers to quickly get an overview of the most important aspects of the insurance.

Furthermore, the information provided is often not standardized. Unlike traditional insurance, where the Insurance Product Information Document (IPID) is often used, embedded insurance often lacks a standardized information document. This makes it difficult for consumers to compare different insurances or to understand the specific terms and conditions.

2.2.2 Information is often presented in a positive light

The information provided is often presented in a positive light, emphasizing the benefits of the insurance while downplaying the limitations and exclusions. This can lead to consumers having an unrealistic expectation of the coverage. For example, the insurance might be presented as providing 'full protection' without clearly stating the exclusions or limitations.

2.3 Choice Pressure: What incentives are added? 2.3.1 Social proof and urgency

Many platforms use social proof and urgency to create choice pressure. Social proof is often used by stating that the insurance is 'most chosen' or by showing the number of people who have concluded the insurance. Urgency is often created by stating that the offer is only available for a limited time or that the price will increase after a certain moment.

2.3.2 Visual and textual cues

Platforms use various visual and textual cues to steer consumers towards concluding an insurance. This includes using striking colors, icons, and text that emphasize security and protection. These cues can subconsciously influence consumers to choose the insurance option.

3. Conclusion The AFM concludes that the current design of many choice environments carries the risk that consumers conclude an insurance that is not suitable for their situation or preferences. The combination of low-threshold enrollment, limited and difficult-to-access information, and the combination of multiple steering elements can lead to consumers being insufficiently able to make a well-considered decision. The AFM therefore emphasizes the importance of a careful design of the choice environment, so that consumer interest is better safeguarded when offering embedded insurance.

4. References AFM, 2025a. [Reference details] AFM, 2025b. [Reference details] AFM, 2021. [Reference details] Bardelo et al., 2013. [Reference details] Hilchey et al., 2023. [Reference details] Krijnen et al., 2017. [Reference details] Mertens et al., 2022. [Reference details] Orquin et al., 2021. [Reference details] Ranyard et al., 2017. [Reference details] Sydnor, 2010. [Reference details] Zhao et al., 2022. [Reference details]