Legal environment

Directive on insurance distribution

Directive (EU) 2016/97 on insurance distribution (Insurance Distribution Directive – IDD) must be applied in the European Union by 1 October 2018 at the latest. The IDD affects all aspects of the insurance business, from recruiting insurance distributors including training and advanced training, to product development, the advisory process including wide-ranging duties to provide information and the distribution of standardised information sheets, all the way to handling conflicts of interest and remuneration. All of the distribution channels used by Vienna Insurance Group and its Group companies, such as salaried field employees, cooperation with insurance intermediaries (brokers and agents) and intermediaries performing distribution as a secondary activity, such as car dealers, are affected. Vienna Insurance Group conducted a Group-wide workshop to assist Group companies in the EU that are affected. Due to high demand, at least one more workshop will be offered. Furthermore, in addition to regular updates for the available legal bases,

Group companies were also provided information and explanatory materials prepared for specific topics in order to create a shared understanding of the interpretation of European legal requirements, which is frequently kept to a very general level. Many questions from individual Group companies concerning local distribution solutions were also answered. As a result synergies were achieved, while simultaneously respecting local, independent implementation by the Group companies.

Regulation on key information documents for packaged retail and insurance-based products (PRIIPs)

Regulation (EU) No. 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs Regulation) must be applied in the European Union as of 1 January 2018. The aim of this regulation is to allow consumers to compare banking, insurance and investment products based on standardised, pre-contractual, non-personalised information sheets. The member states must define their scope at local product level based on general European criteria. VIG companies are generally affected in the area of unit-linked and index-linked life insurance, and in some member states also in the traditional life insurance area. VIG conducted a Group-wide workshop to help affected Group companies in the EU with local, independent implementation of the requirements and to discuss and answer practical questions raised by the Group companies. This ensured that all companies could begin issuing key information documents to customers in a timely fashion.

General Data Protection Regulation

Regulation (EU) No.2016/679 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation – GDPR) enters into force on 25 May 2018 and must therefore be immediately applied in the European Union. The GDPR standardises the provisions applicable to the processing of personal data by private-sector companies and public bodies in the entire EU. The main objectives of the GDPR are data security and strengthening the fundamental rights and freedoms of natural persons. Although the GDPR is immediately applicable across the EU, it nevertheless contains opening clauses that allow member states to enact their own national regulations. The GDPR was implemented in Austrian law by the Austrian Data Protection Amendment Act of 2018 (Datenschutz-Anpassungsgesetz 2018), which extensively amended the Austrian Data Protection Act of 2000 (Datenschutzgesetz 2000).

The GDPR affects the processing of personal data of insurance customers of Vienna Insurance Group and its Group companies. The GDPR requirements were discussed and analysed in detail by the Vienna Insurance Group Data Protection Officer and data protection officers of the local Group companies during a Group-wide workshop, so that all of the affected companies could begin organisational implementation of the data protection provisions in a timely fashion.