IDD Article 10: 15 Hours Training and Who Must Complete It

If you work in insurance distribution in the European Union, one number comes up again and again: at least 15 hours of training or development a year. It comes from Article 10 of the Insurance Distribution Directive, Directive (EU) 2016/97. This guide explains what Article 10 says about knowledge, competence and training, who the training requirement covers according to a European Commission answer published by the European Insurance and Occupational Pensions Authority (EIOPA), and what the article requires beyond training. For the Irish application of these ideas, see our guide to the Central Bank Minimum Competency Code and CPD.

What Article 10 requires on knowledge and competence

According to the EIOPA rulebook, Article 10 sits in Chapter IV of the directive, titled professional and organisational requirements. Under paragraph 1, home Member States must ensure that distributors, and staff of insurers and reinsurers who distribute products, possess appropriate knowledge and ability to do their jobs properly.

The 15-hour benchmark

Paragraph 2 says intermediaries and relevant staff must keep their skills up to date through ongoing training suited to their role and market. Home Member States must publish the mechanisms they use to check and assess competence. These are based on at least 15 hours of training or development per year, adjusted for the products sold, the type of distributor, the person's role and the activity. States may require a certificate as proof of completion. Intermediaries must also meet the competence requirements in Annex I to the directive.

Two points follow from that wording. The 15 hours is a benchmark for the mechanisms states put in place, and it is to be adjusted for the person's role, so it is not a flat number for every individual. And it is about training or development, so what counts depends on how each Member State implements it.

Who has to complete the training

The directive applies Article 10 to employees of insurers and reinsurers who distribute products, to insurance and reinsurance intermediaries and their employees, and to ancillary insurance intermediaries, for whom states may set lighter requirements. States need not apply the requirements to every person doing distribution work, but managers responsible for distribution and anyone directly involved in distribution must show the necessary knowledge and ability.

EIOPA's questions and answers database, entry 2111, deals with this directly. The question, submitted on 19 February 2020, asked whether accountants and administrative staff who do not sell policies but answer policyholder queries or help with requests such as partial surrenders must complete the training. The answer was given by the European Commission rather than EIOPA. It concludes that the requirement applies only to management-level persons responsible for insurance distribution and to other staff who personally carry out distribution activities. The Commission reads directly involved to mean personally performing, or supervising someone who personally performs, distribution activities, which include advising, proposing, preparatory work, concluding contracts, and assisting with contract administration or claims. Accounting and administrative staff who do not perform these activities fall outside the requirement.

The same entry says the answer only clarifies existing law, does not create new rights or obligations, is intended as guidance rather than an authoritative interpretation, and does not bind the Commission's future positions. Only the Court of Justice of the European Union can authoritatively interpret EU law.

Other requirements in Article 10

• Good repute (paragraph 3): anyone doing distribution work must have a clean criminal record, or a national equivalent, for serious offences against property or related financial crimes, and must not have been declared bankrupt unless rehabilitated under national law.
• Professional indemnity (paragraph 4): intermediaries must hold cover for professional negligence across the EU, or an equivalent guarantee, of at least 1,250,000 euro per claim and 1,850,000 euro in total per year, unless the insurer or other undertaking already provides it or takes full responsibility for the intermediary's actions.
• Customer money (paragraph 6): states must choose one or more safeguards, such as treating customer payments to an intermediary as paid to the insurer, requiring financial capacity of 4 percent of annual premiums received with a minimum of 18,750 euro, requiring strictly segregated customer accounts, or requiring a guarantee fund.
• Updating the amounts (paragraph 7): EIOPA reviews the euro amounts in paragraphs 4 and 6 every five years to reflect changes in the Eurostat consumer price index, with the first review due by 31 December 2017.
• Organisational duties (paragraph 8): insurers and reinsurers must approve, implement and regularly review internal policies and procedures to ensure compliance, designate a function to oversee implementation, keep up-to-date records, and give the home state authority the name of the responsible person on request.

Our suggestions for a training record

These are Learnsignal's suggestions, not EIOPA or regulator requirements. Keep a list of everyone who personally performs or supervises distribution activities, using the Commission's definition, and record why anyone is excluded. Check your home Member State's published mechanism for how the 15 hours is counted. Keep certificates and dates for each person. Review the list when roles change. Training for insurance staff is available through Learnsignal CPD, and our guide to insurance distribution intermediaries in Ireland covers the Irish registration and conduct rules.

What we could not confirm

We read the EIOPA rulebook page for Article 10, last updated by EIOPA on 5 July 2024, and one Commission answer, not the Official Journal text of the directive, and we have not checked how any individual Member State has implemented the 15-hour benchmark, including what counts as training and whether certificates are required. The euro amounts in paragraphs 4 and 6 have been indexed since 2017 and the figures above may not be current. We did not review Annex I or the delegated regulation amending the directive.

Frequently asked questions

Is the 15 hours a fixed number for every person?

According to Article 10, the mechanisms are based on at least 15 hours of training or development per year, adjusted for the products sold, the type of distributor, the person's role and the activity.

Do administrative staff need the training?

The Commission's answer in EIOPA entry 2111 says staff who do not personally carry out or supervise distribution activities fall outside the requirement.

Can a Member State require proof of training?

Yes. Article 10 says states may require a certificate as proof of completion.