Insurance product information document / IPID (Art. 20 para. 7 and 8 IDD)

At which level should IPIDs be drafted (this is akin to asking what is meant by “product” since there should be 1 IPID per product)? Should the different coverage levels (gold, silver, platinum, ...) of optional and non-optional guarantees commercialized for a product be disclosed within the same IPID (approach 1 below) or should there be one IPID per level of coverage commercialized for each product (i.e. an IPID for the gold level of coverage of the product, another IPID for the silver level of coverage of the product, another one for the platinum level of coverage of the product) (approach 2 below)?

We have noticed that there are two different approaches regarding the level at which IPIDs are issued – depending on the interpretation of what “an insurance product” is. Please, note that we use the terminology “product typology” hereafter to encompass both products that relate to a single line of business and these that relate to several ones (in case of multi-risks products). - Approach 1: Some insurance undertakings have drafted one IPID per product with one product corresponding to one insurance product typology. For that insurance product typology, there are different levels of non-optional coverages proposed (gold, silver, platinum, ...). However, all of these levels of coverage are summarized within the same IPID but under different sub-sections, titled with the protection level chosen (gold, silver, platinum, ...). Regarding the optional coverages, these are detailed under the sub-sections they apply to and explicitly referred to as “optional”. Therefore, all the levels of coverage are summarized within one single IPID. - Approach 2: Some insurance undertakings have drafted one IPID per product with one product corresponding to one level of non-optional coverage (e.g.; gold or silver or platinum, ...) among the several levels commercialized for this product typology. This leads to the issuance of several IPIDs per insurance product typology: one per level of coverage. Regarding the optional coverages, these are listed within the same IPIDs as for the non-optional guarantees but under a distinct subsection explicitly mentioning their optional characteristics.