MARKET UPDATE: Germany - Broker Disclosure Requirements Introduced

Apr 8
3 min read

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REGULATORY UPDATE SUMMARY

On 23 December 2025, the Agency for Regulation and Development of the Financial Market adopted Resolution No. 82, introducing a key provision that requires that insurance brokers disclose their minimum and maximum commission ranges, as well as any affiliated or formal relationships with (re)insurers.
The disclosure requirements entered into force on 1 February 2026, formalizing enhanced transparency standards within the insurance distribution process.

Historical Context

In the years following the 2008 Global Financial Crisis, regulators across Europe placed greater emphasis on consumer protection, transparency, and aligning financial advice with client interests, ultimately laying the foundation for more structured oversight of insurance distribution.

This direction was formalized through the Insurance Distribution Directive (IDD), which introduced requirements around remuneration disclosure, product governance, and intermediary conduct. While Germany implemented these rules, regulators continued to observe inconsistencies in practice, particularly in the management of conflicts of interest and the documentation of advice.

In response, Germany introduced Resolution No. 82 to close the gap between regulatory intent and real-world practice by reinforcing transparency, formalizing conflict-of-interest controls, and ensuring that advice can be clearly demonstrated and justified.

Germany: Overview Resolution No. 82

Resolution No. 82 introduces enhanced disclosure obligations for insurance brokers, with a focus on transparency in compensation and relationships with insurers.

Brokers must now disclose:

Commission ranges (min. and max. expected remuneration)

Affiliated or official relationships with insurers or reinsurers

The regulation does not prohibit commissions or relationships but requires that they are clearly communicated to clients prior to placement, strengthening governance and informed decision-making.

Implications of Resolution No. 82

Implications for Multinational Insurance

Impact on the Global Economy

Global Implications: This development reflects a continued global shift toward greater transparency in insurance distribution, aligning with broader regulatory trends seen across multiple jurisdictions.

Cross-Border Considerations: For multinational programs, disclosure requirements may vary by jurisdiction, creating inconsistencies in broker transparency standards across global placements.

Broker Network Alignment: Global broker networks will need to ensure that local partners comply with jurisdiction-specific disclosure rules, particularly where local regulations impose stricter requirements.

Market Dynamics: Increased transparency may influence carrier selection, placement strategy, and client expectations, particularly for large corporate buyers.

Global Market Impact

Strategic Takeaway

Resolution No. 82 signals a continued shift toward transparency and accountability within insurance distribution, placing greater emphasis on how advice is delivered, not just the outcomes of placement.

For multinational organizations, the regulation reinforces three realities:

Transparency in broker compensation and relationships is becoming a regulatory expectation, not a best practice

Governance over broker selection and oversight is increasingly critical at the enterprise level

Jurisdictional differences in disclosure requirements will continue to influence global program coordination

Moving forward, expect multinational insurance programs to evolve by embedding transparency, governance, and advisory integrity into their placement and oversight frameworks.

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