Human capital & corporate risk
In March 2024, the AFM published a new interpretation with regard to group insurance. The amended rules concerning group insurance are the result of a ruling by the Court of Justice of the European Union. This interpretation may have consequences for companies that, in addition to their main activity, offer “group insurance” to third parties, such as their customers. In this newsletter, we inform you about this important development from the Financial Markets Authority (AFM).
Group insurance is an insurance contract between a policyholder and an insurer, where the policyholder can add multiple people or companies to the policy as insured persons. Examples of group insurance include:
The policyholder takes out the policy and reports the insured to the insurer. The insured person pays contributions (whether or not via the policyholder). The insurance can automatically apply to all participants, or participants can consciously choose to participate.
From October 1, 2025 in certain situations, a licensing requirement created for policyholders who offer group insurance. This is the case when:
The licensing requirement does not apply if the activities fall under the exemption scheme or article 7 of the Financial Supervision Act (Wft). It is therefore important to assess in time whether your current way of working falls under this exemption, or whether adjustments are necessary.
Using the diagram below, you can determine whether there is a licensing requirement:
Because, as advisors, we have no insight into the agreements between your organization and your contract parties, we ask you to assess with your customers whether there are group policies in your portfolio that may be subject to licensing. Are you unsure about this? Please contact us as soon as possible. Please note that applying for a permit from the AFM lasts at least 13 weeks. A request must therefore before 1 July 2025 to be submitted.
For the full explanation of the AFM, please refer to their website: AFM — Group insurance licensing requirements. Do you have questions and would you like to receive appropriate advice? Then feel free to contact our specialists.
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