Date: 26th May 2021

BETTER FINANCE replied to the European Insurance and Occupational Pension Authority's (EIOPA) public consultation on open insurance, focused on access to and sharing of insurance-related data. In its Discussion Paper, EIOPA explores questions on whether and how far insurance value chains should be ‘opened’ up by the sharing of insurance-related and specific policyholder data amongst insurance and non-insurance firms, to protect policyholder rights and to allow for innovation in products and services.

BETTER FINANCE supports EU-wide public comparison tools. It is well known that financial services users struggle to find and collect information on fees and the performance of financial products. The study on the “distribution system of retail investment products”  reveals that financial services users are discouraged to look for different financial products or due to obstacles and complexity in looking for more suitable products they prefer to remain with their initial financial provider.

Regulators and supervisors should put more focus on independent/public comparison websites allowing financial consumers to easily compare insurance products (and other financial products) in terms of costs and benefits of the services provided.

However, independent comparison tools should not exclusively “compare” price information but should go further and include additional policy features in order to provide a comprehensive picture of the insurance services available.

An open insurance framework could provide a higher degree of transparency and benefits in terms of costs for financial consumers. However, these benefits could be outweighed by risks related to the use of data. Data should be treated in a fair and non-discriminatory way. Therefore, any policy implementation on open insurance should be accompanied by safeguards to protect consumer data.