Who adheres to the AAS

Insurance undertakings and intermediaries pursuing business in Italy must adhere to the Insurance Ombudsman (AAS) and automatically join it.

It is important to know that...

Insurance intermediaries are professionals who act as liaisons between insurance companies and customers, helping them to choose policies that are suitable for their insurance needs. All the intermediaries must be registered in the Single Register of Intermediaries (RUI) or, if they have their head office in another country of the European Economic Area (EEA) and carry on business in Italy under the free provision of services or the right of establishment, in the List enclosed to the RUI, accessible at this link.

More in detail:

  • agents (sect. A of the RUI) work for one or more insurance undertakings, promoting and selling their products. The premium payment made by the customer to the agent and/or their collaborator directly binds the undertaking;
  • brokers (sect. B of the RUI) act on behalf of the client and do not represent a specific company, which allows them to offer policies from different undertakings on the market. Be careful: the premium payment made by the customer to the broker and/or their collaborator directly binds the undertaking only when this is expressly provided in the agreement between the broker and the undertaking;
  • direct canvassers (sect. C of the RUI) work exclusively for an insurance undertaking in the placement of life or health insurance policies;
  • banks, financial companies and Poste Italiane (sect. D of the RUI), when carrying out their main activity, may also pursue insurance mediation. For example, your bank might offer you home insurance linked to a mortgage;
  • ancillary intermediaries (sect. F of the RUI) offer policies linked to a main product or service. For example, when you buy a household appliance, the shop itself may offer you insurance against any damage or breakdown. Similarly, a travel agency might offer you a travel policy to cover unforeseen events affecting your holiday;
  • foreign intermediaries, with head office in another EEA country, can pursue business in Italy under the right of establishment or the freedom to provide services (List annexed to the RUI).

All the insurance intermediaries, with the exception of direct canvassers, can use collaborators (sect. E of the RUI), who work under their supervision and support them in the promotion and sale of insurance products.

Intermediaries registered in sections A, B and D of the RUI, as well as foreign intermediaries, may enter into agreements with each other for the pursuit of insurance mediation. This is referred to as horizontal collaborations. Within the scope of a horizontal collaboration a distinction is made between:

  1. the issuing intermediary, i.e. the intermediary that has received the distribution mandate from the insurance company or has an agreement with it to offer insurance products;
  2. the proposing intermediary, i.e. the intermediary who comes into direct contact with the customer, explains the product characteristics, provides information and takes care of the underwriting activities, and so on.

For example, a bank and a broker might agree for the broker to market an insurance-based investment product offered by an insurance company with respect to which the bank holds the distribution mandate. In this case, the bank is the issuing intermediary, the broker - who actually comes into contact with customers - is the proposing intermediary.

An exception to the rule of automatic membership of the AAS is made for insurance undertakings and intermediaries with their registered office or residence in another country of the European Economic Area (EEA) that pursue business in Italy under the freedom to provide services (FoS): these entities are required to adhere to the AAS unless they state otherwise, specifying the name of the alternative dispute resolution system they adhere to in the country of origin, which is part of FIN-NET.

It is important to know that...

The European Economic Area (EEA) is an area which includes all member states of the European Union, plus three non-member states: Norway, Iceland and Liechtenstein.

Insurance undertakings and intermediaries with their registered office in one of these countries may pursue business in other EEA Member States in two ways: opening a branch office in the host country (right of establishment) or using other distribution channels, such as a website, without opening physical office in the host country (free provision of services or “FoS”).

To find out the foreign insurance undertakings carrying on business in Italy by way of establishment or FoS you can consult, respectively, List I and List II attached to the Register of undertakings, accessible at this link. With particular regard to motor vehicle liability, a special list is available that can be consulted on IVASS website at this link. To find out the foreign intermediaries carrying on business in Italy by way of establishment or FoS you can consult the List attached to the RUI, accessible at this link.

For more information, consult the section ‘Registers’ on IVASS' website.