Digitization in the insurance industry is moving at incredibly fast pace - and it is becoming not only more difficult for regulators to keep up and apply the approach developed for another, non-digital era. Likewise, it is becoming more difficult for businesses in the insurance industry to comply with the various consumer protection rules and assess the impact of new legislative developments. From a legal perspective, and in view of the significant penalties, the objective needs to be to ensure that (all) e-commerce regulation is complied with. The Omnibus Directive, also known as the New Deal for Consumers, will introduce significant changes to existing consumer protection legislation, in particular the building-out of existing, and introduction of new, obligations on traders and online platforms designed to give further protection to consumers. While it is (and will remain) not only important to ensure that all relevant product information is provided to the customer, such information will also need to be be relevant and presented in an easy-to-understand manner. The decisive question will be: Will the consumer understand what is presented to him, not whether the information was at all provided. Terms and conditions in particular in the insurance industry are often couched in complex legal language, presented in small print or hidden behind a link, making them difficult to read especially on mobile devices. Is it time for a change, time to re-consider the customer experience?
Established insurers are investing heavily in digitizing their customer journeys and processes, and numerous new, purely digital insurers, or insurtechs, have entered the market.