Clifford Chance

CAA guidance note on the notion of insurance intermediary in the context of collective insurance contracts

31 January 2024

On 24 January 2024, the Luxembourg insurance sector supervisory authority Commissariat aux assurances ("CAA") published its Information Note 24/1 (the "Information Note") which clarifies the notion of insurance intermediary in the context of collective insurance contracts. In its Information Note, the CAA provides guidance on how the recent decision of the Court of Justice of the European Union 'TC Medical Air Ambulance Agency' (decision C-633/20 of 29 September 2022) should apply in a Luxembourg context and confirms that a subscriber of a collective insurance contract ("sponsor") may qualify as 'intermediary' additionally to being the policyholder of such contract in relation to the insurance undertaking. Clifford Chance in Luxembourg has produced a client briefing on the new Information Note of the CAA and action points for insurance undertakings and sponsors concerned.

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