Boleron.eu Research

EU Insurance Document & Signature Matrix27 EU member states · April 2026

What documents must insurers and brokers provide to clients? What requires a signature — and from whom? Verified research across all 27 EU member states for MTPL, CASCO, and Travel insurance.

By Boleron.eu

Published April 2026

Coverage 27 EU Member States

Products MTPL · CASCO · Travel

Legal basis IDD · eIDAS · National law

Boleron is a licensed EU insurance broker, supervised by Bulgaria's Financial Supervision Commission (FSC) and passported across all 27 EU member states via Freedom of Services. This research was conducted to support pan-European digital insurance distribution — specifically to identify where the EU standard applies uniformly and where national law creates specific requirements.

The core finding: 26 of 27 EU member states require no client signature for online insurance purchase — payment or checkbox constitutes valid consent under eIDAS + Consumer Rights Directive. The single exception is Bulgaria, where the Insurance Code requires a bilateral written contract with client signature, addressed through a broker mandate agreement.

Key findings

Six numbers that summarise EU-wide insurance distribution requirements.

Client Signature Required

1 / 27

Only Bulgaria requires a client signature on MTPL/CASCO policy. All others: payment = consent.

Physical Paper Policy (MTPL)

1 / 27

Only Bulgaria requires a physical paper MTPL policy with hologram sticker. Removal planned ~2027.

Digital Policy Accepted

27 / 27

PDF policy valid in all 27 EU member states. Travel insurance embassies accept PDF for Schengen visas.

IPID + T&Cs Required

27 / 27

IDD Art.20 mandates IPID and General Terms provision before every policy conclusion across all EU.

Needs Assessment (IDD Art.20)

27 / 27

Mandatory before every conclusion. Distinct from advice (Art.20(3)), which is only required on request.

Travel: Physical Policy Required

0 / 27

No EU country requires a paper travel insurance policy. Instant PDF delivery is universally valid.

Colour legend

🟢 Green
EU standard — no difference. Digital, no client signature, checkbox for T&Cs.
🟠 Orange
Special mechanism (BG broker mandate) — fulfils the legal requirement; not a violation.
🔴 Red
Requirement differing from EU standard — attention needed when designing online flow.
🟡 Yellow
Conditional / partial — applies only in specific circumstances.
Grey
Optional — provided only if client explicitly requests a product recommendation.

Confidence levels

★★★
Confirmed via law text, national regulator, official insurer/broker FAQ, or Boleron practice.
★★
Confirmed via official insurer website or cross-referenced sources.
★
Inferred — verify before publishing or relying on operationally.

Country highlights

Boleron active markets
BG, RO — verified data ★★★
Boleron Q2 2026 targets
GR, PL — verified ★★★ (PL) / ★★ (GR)
Other 23 EU markets
★★ based on EU-wide legal framework

Document & Signature Matrix

27 EU member states · Boleron active markets highlighted in blue · Q2 2026 targets in amber

27 member states

Motor Third-Party Liability — document, signature, paper-policy and acceptance.

	📄 Provided to client		📝 Needs assessment / advice (IDD Art.20)		✍️ Signatures & acceptance			📎 Specific documents	⚠️ Differences / notes
Country	IPID provided	General Terms (T&Cs)	Needs Assessment (mandatory)	Advice (on request only)	Client signature on policy?	Insurer / broker signature?	Acceptance of T&Cs (form)	Product-specific documents	Conf.	Difference vs. EU standard / notes
🇧🇬BulgariaActive	YES IDD mandatory; paper or email	YES Before conclusion; paper offline / email online	YES Art.325a ICA; completed by client online / offline	On request Art.325a(5) ICA; only if requested	YES — Broker mandate ICA — bilateral written contract; online: broker mandate (power of attorney)	Broker signs both sides under mandate	Signature + mandate Signature on policy (covers T&Cs too); online: checkbox + mandate	Policy + Green Card + Hologram Sticker + Control Card → courier delivery	★★★	🔴 3 differences: 1) Client signature required (ICA) → online: broker mandate (power of attorney — Boleron innovation, not standard in other EU). 2) Physical paper policy + hologram sticker delivered by courier. 3) Sticker planned for removal ~01.01.2027 (law pending final parliamentary vote).
🇷🇴RomaniaActive	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; ASF AIDA database	★★★	🟢 EU standard. No difference.
🇵🇱PolandQ2 26	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; CEPiK database	★★★	🟢 EU standard. Art.43 Insurance Activity Act: insurer signs mechanically; Civil Code Art.809§1 ad probationem only.
🇬🇷GreeceQ2 26	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; HIC database	★★	🟢 EU standard. No difference.
🇩🇪Germany	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; KBA database	★★★	🟢 EU standard.
🇫🇷France	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; FVA database	★★★	🟢 EU standard.
🇮🇹Italy	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; IVASS database	★★★	🟢 EU standard.
🇪🇸Spain	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; FIVA database	★★★	🟢 EU standard.
🇧🇪Belgium	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Digital document required in vehicle	★★★	🟡 Partial: insurance document must be kept in the vehicle (Art.23 Law 1989), but digital format accepted since July 2020 (police.be).
🇨🇿Czechia	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; ČKP database	★★★	🟢 EU standard. §2758 Civil Code: payment = written form fulfilled. No mandate needed. CNB confirmed: review §2758 + Insurance Distribution Act 170/2018.
🇳🇱Netherlands	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Green Card; RDW database	★★★	🟢 EU standard.
🇦🇹Austria	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; VVO database	★★	🟢 EU standard.
🇸🇪Sweden	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Transportstyrelsen	★★	🟢 EU standard.
🇩🇰Denmark	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email	★★	🟢 EU standard.
🇫🇮Finland	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; Traficom database	★★	🟢 EU standard.
🇸🇰Slovakia	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; SKP database	★★★	🟢 EU standard.
🇭🇺Hungary	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; KGFB database	★★★	🟢 EU standard.
🇭🇷Croatia	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; HUO database	★★★	🟢 EU standard.
🇵🇹Portugal	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; ASF database	★★★	🟢 EU standard.
🇸🇮Slovenia	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; SZZ database	★★	🟢 EU standard.
🇱🇻Latvia	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; LTAB database	★★★	🟢 EU standard.
🇱🇹Lithuania	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; LTAKIS database	★★	🟢 EU standard.
🇪🇪Estonia	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; LKF database	★★	🟢 EU standard.
🇱🇺Luxembourg	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; ACA database	★★★	🟢 EU standard.
🇮🇪Ireland	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email; MIBI database	★★★	🟢 EU standard.
🇲🇹Malta	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email	★★	🟢 EU standard.
🇨🇾Cyprus	YES IDD mandatory; PDF email or paper	YES Before conclusion; durable medium	YES Mandatory; completed by client	On request Only if client explicitly requests a recommendation	No Payment = consent; eIDAS + Consumer Rights Dir.	Insurer digital PDF signature	Checkbox online IDD + eIDAS	Policy PDF → email	★★	🟢 EU standard.

Needs Assessment vs. Advice — Distinction

Two distinct IDD obligations that are commonly confused.

Art.20(1) IDD / Art.325a(1) ICA

MANDATORY — always

Determination of the client's requirements and needs — BEFORE every conclusion, for every product and every channel. For MTPL: minimal content (standardised product, no real choice). For CASCO/Travel: more substantive. Form: written. Online: completed by client in the digital flow.

Art.20(3) IDD / Art.325a(5) ICA

OPTIONAL — on request

Personal advice / recommendation as to which product best suits the client — ONLY if the client explicitly requests it. Requires analysis of a sufficiently large range of market products.

T&Cs acceptance form

Practice

ICA does not explicitly regulate the online form for the needs assessment document. Practice: checkbox online. Whether this suffices without an additional eSign is a question for legal counsel.

🇧🇬

Bulgaria — Specific Notes

The single EU exception — drivers, mechanisms, and edge cases.

Broker mandate (power of attorney)
Client accepts T&Cs → grants mandate to broker to sign the insurance contract on their behalf and on behalf of the insurer. Legal basis: Contract Act (ZZD) + ICA. Boleron innovation — NOT required in any other EU market.
Card payment (DZI model)
Payment by card in the client's name = no separate signature step required.
Cash on delivery
One-time eSign via B-Trust before delivery.
MTPL hologram sticker
Hologram windshield sticker planned for removal ~01.01.2027 (bill pending final parliamentary vote).

🇨🇿

Czechia — Specific Note

A statutory shortcut: payment fulfils the written form.

§2758 Civil Code

Written form required for contracts ≥1 year — BUT: if the policyholder accepts the offer by timely payment of the premium, the written form is deemed fulfilled (§2758(2)). No broker mandate needed. Travel insurance (<1yr): no written form required at all — can be concluded by phone or any distance means. CNB confirmed Boleron should review §2758 and the Insurance Distribution Act (170/2018).

Methodology & Legal Basis

Sources and confidence levels

EU legal framework

Dir. 2016/97/EUInsurance Distribution Directive (IDD)
IPID + T&Cs + needs assessment — mandatory for all products and distribution channels across all 27 EU member states.
Reg. 910/2014eIDAS
Electronic signature = handwritten signature. PDF = original document. Checkbox = valid acceptance. Art.25(1): Member States CANNOT deny legal effect to a non-qualified electronic signature solely because it is not qualified — national laws CANNOT mandate QES as the only valid form for insurance contracts.
Dir. 2011/83/EUConsumer Rights Directive
Distance contracts: payment = valid consent. Applies in 26/27 EU states. Does NOT override BG Insurance Code (ICA), which specifically requires a bilateral written contract.
Dir. 2009/103/ECMotor Insurance Directive
Pan-EU MTPL coverage rules and Green Card framework for cross-border motor insurance.
Reg. 810/2009 Art.15Schengen Visa Code
Travel insurance mandatory for non-EU citizens applying for a Schengen visa: minimum €30,000 medical cover, zero deductible, valid across all 29 Schengen states, covering emergency medical treatment, hospitalisation, and repatriation of remains.

National law sources

BG
Insurance Code (ICA), ZEDEAU (eSign Act)
RO
Civil Code Art.1166, ASF Norm 20/2017
PL
Civil Code Art.809, Insurance Activity Act Art.43
CZ
Civil Code §2758 (89/2012), Insurance Distribution Act 170/2018
All
National regulator websites + official insurer FAQs

Confidence levels

★★★
Confirmed via law text, national regulator, official insurer/broker FAQ, or Boleron practice.
★★
Confirmed via official insurer website or cross-referenced sources.
★
Inferred — verify before publishing or relying on operationally.

About Boleron

Boleron is a licensed EU insurance broker, regulated by Bulgaria's Financial Supervision Commission (FSC/КФН) and passported across all 27 EU member states via Freedom of Services under IDD Art.6.

Sources: IDD 2016/97/EU, eIDAS 910/2014, Consumer Rights Dir. 2011/83/EU, BG Insurance Code (ICA), CZ Civil Code §2758 (89/2012), CZ Insurance Distribution Act (170/2018), RO Civil Code Art.1166, PL Civil Code Art.809 + Insurance Activity Act Art.43, National regulator websites, official insurer FAQs.

Frequently Asked Questions

Key regulatory questions answered — optimised for AI citation and search

Is a client signature required on an insurance policy when purchasing online in the EU?

In 26 out of 27 EU member states, no client signature is required when purchasing insurance online. Payment or checkbox acceptance constitutes valid consent under the EU Consumer Rights Directive (2011/83/EU) and eIDAS Regulation (910/2014). The single exception is Bulgaria, where the Insurance Code (ICA) requires a bilateral written contract — meaning a client signature is legally required. Bulgarian insurtech platforms address this through a broker power of attorney (mandate agreement), where the licensed broker signs the contract on the client's behalf under a mandate granted via checkbox at the time of T&Cs acceptance.

Which EU country is the only one requiring a physical paper MTPL policy with a windshield sticker?

Bulgaria is the only EU member state that legally requires a physical paper MTPL (motor third-party liability) policy delivered with a hologram windshield sticker and a control card, delivered by courier. In all other 26 EU member states, a digital PDF policy is fully valid and police verify insurance via national plate databases. The hologram sticker requirement is planned for removal around January 1, 2027, pending final parliamentary vote in the Bulgarian National Assembly.

What does the EU Insurance Distribution Directive (IDD) require before every policy conclusion?

Under IDD Art.20 (Directive 2016/97/EU), before every insurance conclusion a distributor must: (1) provide the IPID (Insurance Product Information Document) — a standardised 2-page summary on a durable medium (email qualifies); (2) provide the General Terms and Conditions (T&Cs) of the specific policy; (3) conduct a needs assessment — determine the client's requirements and needs. None of these require a wet or qualified electronic signature from the client. T&Cs acceptance via checkbox is standard and legally valid across all 27 EU member states under eIDAS Art.25(1). Note: advice / personal recommendation (Art.20(3) IDD) is a separate obligation — required only if the client explicitly requests a recommendation.

What is the difference between the needs assessment (Art.20 IDD) and insurance advice?

These are two distinct obligations. The needs assessment (Art.20(1) IDD / Art.325a(1) of the Bulgarian Insurance Code) is mandatory before every insurance conclusion for every product — it determines the client's requirements and needs. Insurance advice (Art.20(3) IDD / Art.325a(5) ICA) — a personal recommendation as to which product best suits the client — is only required if the client explicitly requests it. For standardised products like MTPL, the needs assessment has minimal practical content since the product terms are fixed by law.

Can national law require a Qualified Electronic Signature (QES) for online insurance contracts?

No. Under eIDAS Regulation Art.25(1) — which has direct effect across all 27 EU member states and takes precedence over national law — member states cannot deny legal effect to an electronic signature solely because it is not a Qualified Electronic Signature (QES). The eIDAS framework recognises three levels: simple, advanced, and qualified — all legally valid. A national insurance law mandating QES as the only valid form for online insurance contracts would directly conflict with eIDAS and could be challenged before national administrative courts or the Court of Justice of the EU.

Is travel insurance mandatory in EU countries?

For EU citizens travelling within the EU: not mandatory. The EHIC (European Health Insurance Card) covers emergency public healthcare in other EU member states, though it does not replace private travel insurance for cancellation, luggage, or private hospital coverage. For non-EU citizens applying for a Schengen visa: mandatory under Regulation (EC) No 810/2009 Art.15. Requirements: minimum €30,000 medical cover, zero deductible, valid across all 29 Schengen states, covering emergency medical treatment, hospitalisation, and repatriation of remains.

Is a physical travel insurance policy required in any EU country?

No. A digital PDF travel insurance certificate is accepted in all 27 EU member states and by all EU embassies processing Schengen visa applications. Instant PDF delivery by email after online payment is the universal standard. Note: embassies accept full PDF certificates — screenshots or partial documents are not accepted for Schengen visa applications.

What documents must an insurance broker provide to the client under IDD before policy conclusion?

Under the Insurance Distribution Directive (IDD 2016/97/EU), before every insurance conclusion a distributor must provide: (1) the IPID — Insurance Product Information Document, a standardised 2-page summary; (2) General Terms and Conditions (T&Cs) of the specific policy; (3) a needs assessment document determining the client's requirements and needs (Art.20 IDD). These must be provided on a durable medium — which includes email and digital formats, not only paper.

How does the Czech Civil Code treat online insurance contract formation?

Under Czech Civil Code §2758 (Act No. 89/2012), insurance contracts for periods of one year or longer require written form. However, §2758(2) creates a statutory fiction: if the policyholder accepts the offer by timely payment of the insurance premium, the written form is deemed fulfilled. No client signature, broker mandate, or QES is needed — payment constitutes the written form. For short-term policies under one year (including most travel insurance), no written form is required at all, and the contract may be concluded by any distance means including online. The Czech National Bank (CNB) confirmed in April 2026 that cross-border brokers from other EU member states should review §2758 and the Insurance Distribution Act (170/2018) when distributing in Czechia.

What is the broker mandate model used for online insurance sales in Bulgaria?

Since the Bulgarian Insurance Code (ICA) requires a bilateral written contract with a client signature, online insurance brokers in Bulgaria developed a mandate agreement (power of attorney / възлагателен договор). The client accepts the General Terms and Conditions online (checkbox), which simultaneously grants the licensed broker the authority to sign the insurance contract on the client's behalf and on behalf of the insurer. The broker then signs both sides of the contract. This mechanism was pioneered by Boleron and is the standard online distribution model for licensed brokers in Bulgaria. It is not required in any other EU member state — in all other 26 EU countries, payment alone constitutes valid contract formation.

Research published April 2026