Germany Regulatory Update: Broker Disclosure Requirements Introduced
- Jul 21
- 4 min read
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GERMANY: REGULATORY UPDATE
Broker Disclosure Requirements Introduced
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.
Overview of the New Resolution
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.
WHAT THIS MEANS FOR MULTINATIONAL BROKERS & INSURERS
Implications of the New Regulation
There are five major changes that will come into effect with this new resolution. Moving forward, brokers and insurers will be expected to provide:
WHAT THIS MEANS FOR MULTINATIONAL ORGANIZATIONS
Implications for Multinational Organizations
For multinational organizations, these changes may have implications that extend beyond tax compliance. They can influence how global insurance programs are structured, how profits and risk are allocated across jurisdictions, and how organizations document and govern cross-border activities.
Global Market Impacts
WHY THESE CHANGES ARE GLOBALLY SIGNIFICANT
Resolution No. 82 reflects a broader trend toward increased regulatory oversight and jurisdiction-specific insurance requirements. For the global insurance industry, it reinforces the need for stronger local compliance, more coordinated multinational program design, and greater reliance on specialized expertise to manage cross-border insurance exposures.
While Resolution No. 82 applies specifically to the German market, its implications extend beyond Germany. For multinational organizations, regulatory changes in individual jurisdictions can affect how global insurance programs are structured, coordinated, and managed across borders.
The resolution also reflects a broader shift toward greater regulatory oversight and jurisdiction-specific requirements. As local insurance rules become more detailed, organizations must balance the consistency of a global insurance strategy with the regulatory, coverage, and compliance requirements of each country in which they operate.
For the global insurance market, this reinforces the importance of local expertise, coordinated multinational program design, and ongoing regulatory oversight.
→ Increased Regulatory Complexity
As Germany introduces new requirements or clarifications through Resolution No. 82, insurers and multinational organizations must ensure their programs remain aligned with local regulatory expectations and supervisory standards.
What this means:
Global insurance programs may require additional review and oversight to maintain compliance within the German market.
→ Greater Focus on Local Compliance
The resolution reinforces the importance of understanding jurisdiction-specific requirements rather than relying solely on global insurance strategies.
What this means:
Insurers and multinational organizations may need to strengthen local compliance reviews and ensure German exposures are addressed through appropriately structured local coverage.
→ Changes to Underwriting & Program Design
New regulatory requirements often influence underwriting practices, policy structures, and coverage design, particularly for multinational programs operating across multiple jurisdictions.
What this means:
Insurers may need to adjust underwriting criteria, policy wording, and program structures to reflect evolving German regulatory expectations.
→ Increased Demand for Multinational Expertise
Italy now represents a jurisdiction where public-official liability coverage is not optional but statutorily required. For multinational companies, this adds complexity to global program design, requiring coordination between risk managers, brokers, and local insurers.
Consideration must be given to locally admitted policies, appropriate limits, and potential difference-in-conditions or difference-in-limits structures to ensure compliance and seamless coverage.
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:
Over time, the reform could also influence broader European discussions around public-official liability and risk transfer mechanisms.
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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