Methodological Guidance of the Supervisory Departments for the Financial Market of the National Bank of Slovakia No. 6/2026 on the Application of the Exemption for Supplementary Insurance Intermediaries

Part 32/2026 NBS Bulletin – Methodological Guidance 1
_________________________________________________________________________________________ Methodological Guidance of the Supervisory Departments for the Financial Market of the National Bank of Slovakia dated 7 September 2026 No. 6/2026 on the application of the exemption for supplementary insurance intermediaries

Pursuant to Section 11c(1) of Act No. 186/2009 Coll. on Financial Intermediation and Financial Advisory and on Amendments to Certain Acts, as amended (hereinafter referred to as the "Act"), a supplementary insurance intermediary is understood to be a person other than a bank, a securities dealer, or an investment management company, which performs financial intermediation in the insurance or reinsurance sector as a supplementary activity for remuneration, provided that the following conditions are met:
a) its main profit-making activity is not financial intermediation or financial advisory in the insurance sector, b) the person offers only insurance products that are supplementary to goods or services, and c) the relevant insurance products do not include life insurance or risks arising from liability; this condition shall not apply if these insurance products are supplementary to goods or services that the person offers as part of its main profit-making activity.

A supplementary insurance intermediary is therefore an entity that sells insurance products as part of a side business activity, whereby the insurance products are supplementary to goods or services of which it is a supplier.

The rules governing the activity of a subordinate financial agent pursuant to Section 9 of the Act or a tied agent pursuant to Section 8 of the Act (depending on the proposer) apply to a supplementary insurance intermediary.

Pursuant to Section 1(3)(b) of the Act, the Act does not apply to a supplementary insurance intermediary if the following conditions are met simultaneously:

1. the insurance is supplementary to goods or services of the supplier, if such insurance covers:
   1a. the risk of breakdown, loss, or damage to goods, or non-use of a service provided by this supplier, or 1b. damage to or loss of luggage and other risks associated with travel booked with this supplier,
2. the amount of premium paid for the insurance product does not exceed the sum of 600 euros calculated proportionally on an annual basis, or if the insurance is supplementary to the service mentioned in point 1 and the duration of this service does not exceed three months, and the premium paid per person does not exceed the sum of 200 euros.

The National Bank of Slovakia holds the view that even in cases where the aforementioned exemption applies, client protection in the distribution of insurance is ensured through its independent financial agent, who has a contract with the supplementary insurance intermediary.

Section 33(14) of the Act stipulates that at least before concluding the contract, the independent financial agent is obliged to provide the client with information on:

• the supplementary insurance intermediary, and
• the procedure for lodging complaints.

In this regard, the independent financial agent is also obliged to:

• present the client with an information document on the insurance product, and

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• have measures in place to ensure compliance with regulatory requirements on advertising and promotion, client assessment, and cross-selling.

Pursuant to Section 70(2)(d) of Act No. 39/2015 Coll. on Insurance and on Amendments to Certain Acts, as amended, if an insurance company uses the services of supplementary insurance intermediaries operating under the exemption, the insurance company is obliged to ensure compliance with the requirements under the Act. At the same time, pursuant to point (e) of the same paragraph, the insurance company is obliged to ensure compliance with the requirements under the Act in the sale of its own insurance products.

The National Bank of Slovakia therefore derives from the aforementioned paragraph that the aforementioned informational and organizational obligations also apply to the insurance company if the supplementary insurance intermediary is in a direct distribution relationship with the insurance company without the involvement of an independent financial agent.

However, the application of the subject exemption also raises other practical questions, such as:

1. Is a supplementary insurance intermediary under the exemption obliged to have a contract concluded with an insurance company or an independent financial agent?

The National Bank of Slovakia holds the view that the existence of a contract between the supplementary insurance intermediary under the exemption and an independent financial agent or insurance company is necessary to fulfill the informational obligations regarding client protection, which the Act imposes on the independent financial agent and the insurance company in the distribution of insurance (primarily Section 33(7) and (14) of the Act). However, it is not excluded that the subject obligations, or some of them, are performed by the supplementary insurance intermediary in relation to the client (e.g., provision of an information document on the insurance product) precisely on the basis of such a contract.

2. Is a supplementary insurance intermediary obliged to meet the requirements for professional competence and reliability even if it performs regulated activity exclusively under the exemption?
   Does an independent financial agent or insurance company monitor the activity of such an intermediary?

The Act does not directly stipulate that a supplementary insurance intermediary under the exemption must meet the requirements for professional competence and reliability within the meaning of the Act. In practice, however, it is reasonable to expect that such an intermediary (at least the person responsible for the distribution of supplementary insurance) has full knowledge of the insurance product it distributes, i.e., understands the product in question. For this purpose, the Independent Financial Agent (IFA) or insurance company has measures in place, which are, for example, part of internal regulations governing rules of contact with clients and potential clients.

The National Bank of Slovakia expects that for this purpose, the independent financial agent or insurance company has established appropriate measures, which are taken into account in the contract concluded with the supplementary insurance intermediary.

The subject measures concern at least:
a) training of the supplementary insurance intermediary on distributed products to ensure basic knowledge, and b) monitoring of distribution under the exemption, including control mechanisms aimed at preventing the distribution of supplementary insurance beyond the scope of the exemption.

3. Is a supplementary insurance intermediary under the exemption obliged to be registered in the relevant register maintained by the National Bank of Slovakia?

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The National Bank of Slovakia holds the view that a supplementary insurance intermediary operating under the exemption is not obliged to be registered in the register.

4. Is a supplementary insurance intermediary authorized to receive remuneration from the client for the performance of insurance intermediation under the exemption?

The National Bank of Slovakia holds the view that the prohibition on receiving monetary or non-monetary consideration from the client does not apply to a supplementary insurance intermediary under the exemption.

5. How should a supplementary insurance intermediary operating under the exemption approach cases where the limits stated in the exemption would be exceeded?

If a potential business case were to arise in the activity of a supplementary insurance intermediary under the exemption that would exceed the legal limits binding on the exemption (e.g., the premium would exceed 600 EUR on an annual basis), such a business case, i.e., the intermediation of supplementary insurance, could not be executed by the supplementary insurance intermediary under the exemption.

For its execution, fulfillment of the regulatory obligations imposed on a subordinate financial agent or tied financial agent in full scope would be required (e.g., professional competence or registration in the register).

The National Bank of Slovakia expects that in such a case, the independent financial agent will without undue delay carry out the steps necessary to register the supplementary insurance intermediary in the register and ensure the permanent fulfillment of the subject regulatory obligations.

Vladimír Dvořáček s. r.
Member of the Board and Executive Director for Supervision and Financial Stability National Bank of Slovakia

Júlia Čillíková s. r.
Executive Director for Supervision and Protection of Financial Consumers National Bank of Slovakia