Insurance Europe responds to the European Commission’s Digital Fairness Act public consultation

Insurance Europe has published today a position paper in response to the European Commission's (EC) public consultation on the Digital Fairness Act (DFA).

The industry welcomes the EC's efforts to ensure a fair digital environment for consumers, but stresses that any potential new rules must recognise that insurance is already subject to robust horizontal and sector-specific legislations that provide strong safeguards for consumer protection.

In its paper, Insurance Europe highlights three key messages:

• Use of data and risk-based underwriting: The DFA must respect the principle of risk-based underwriting, which ensures fair and proportionate pricing based on the individual consumer's level of risk. Any new rules should avoid creating restrictions that would undermine this core mechanism and disrupt the proper functioning of the insurance model.
• Gamification and scoring systems: The DFA should not inadvertently prevent insurers from using gamified tools and scoring systems as these improve financial literacy, promote risk prevention and reward safe or sustainable behaviour, such as through telematics insurance.
• Influencer marketing: The DFA should acknowledge that insurance marketing is already governed by strict sectoral rules under the Insurance Distribution Directive (IDD), with additional safeguards to be introduced by the Retail Investment Strategy (RIS). Adding further requirements would create unnecessary overlap and inconsistency.

Read our full response here: Insurance Europe's position paper on the European Commission's (EC) public consultation on the Digital Fairness Act (DFA) proposal