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. Bill to remove the sticker failed in the National Assembly vote (July 2025); no confirmed removal date.

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
CountryIPID providedGeneral Terms (T&Cs)Needs Assessment (mandatory)Advice (on request only)Client signature on policy?Insurer / broker signature?Acceptance of T&Cs (form)Product-specific documentsConf.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 remains mandatory under Bulgarian law (ZDP); bill to remove it was voted on in the National Assembly in July 2025 but did not pass. No confirmed removal date.
🇷🇴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; Dienstverleningsdocument (NL) on website★★★🟡 Dienstverleningsdocument (Art.86f Wft/BGfo) required: one-page document in Dutch, published on website and sent before purchase. Contains broker identity, independence status, remuneration, shareholding interests. Provisieverbod (commission ban) does not apply to MTPL, CASCO or Travel insurance — only to life, disability and investment products. AFM confirmed May 2026.
🇦🇹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

    Sticker on windshield remains mandatory (Bulgarian law, ZDP). A bill to remove it was voted on in the National Assembly in July 2025 but did not pass. No confirmed removal date.

🇨🇿

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).

Withdrawal Right & Withdrawal Button (DSD 2023/2673)

EU distance selling of financial services — applies across all 27 member states from 19 June 2026.

Directive

Directive 2023/2673/EU on distance selling of financial services

Applies from

19 June 2026 — direct effect (applies even without national transposition)

Replaces

Directive 2002/65/EC

Amends

Consumer Rights Directive 2011/83/EU

Key requirements (all 27 EU markets)

  • 14-day right of withdrawal

    14-day right of withdrawal for distance-concluded insurance contracts across all 27 EU markets.

  • Online withdrawal button mandatory

    Clearly labelled, easy to find, available throughout the withdrawal period. Must be as easy to use as the conclusion flow (symmetry principle).

  • Confirmation on durable medium

    Confirmation of withdrawal on a durable medium (email) immediately after submission.

  • Refund within 30 days

    Refund within 30 days. Client pays only for the service actually provided before withdrawal.

  • MTPL — uninsured-vehicle warning

    Withdrawal right exists, but the vehicle immediately becomes uninsured. The online flow must show the warning: "Withdrawing from MTPL leaves your vehicle uninsured. You must purchase a new policy immediately."

  • Travel insurance < 1 month — exempt

    Travel insurance with cover under 1 month is exempt from the withdrawal right.

  • Annual travel insurance — 14-day withdrawal applies

    Annual travel insurance policies fall under the standard 14-day withdrawal regime.

Transposition status — as of May 2026

  • Transposed

    Germany, France

  • Missed deadline

    Ireland — EC formal notice issued

  • In public consultation

    Bulgaria — ZZP amendment not yet law

  • Unknown

    All other member states — applying from 19.06.2026 regardless (direct effect)

Direct effect applies from 19 June 2026 regardless of national transposition status.

Language Requirements for Insurance Documents

EU baseline: IDD does not mandate a specific language. Several member states have introduced language requirements as 'general good' provisions.

Source: EIOPA + national regulator responses (verified May 2026).

CountryRequirementConfirmed byConfidenceAction for Boleron
🇫🇷FranceMANDATORY: French required for all consumer documents (Loi Toubon 1994). Criminal offence to provide only English. Fine up to €3,750.Law 94-665★★★Translate all IPID, T&Cs, policy to French before FR launch.
🇧🇪BelgiumMANDATORY by region: Dutch (Flanders), French (Wallonia), both (Brussels).Regional language laws★★★Detect client region; serve correct language version.
🇱🇺LuxembourgMANDATORY: French or German required.Official Language Law★★★Provide FR or DE version of all documents.
🇫🇮FinlandCONDITIONAL: Finnish or Swedish required UNLESS client explicitly consents to English.FIN-FSA General Good memo (March 2025)★★★Add language consent checkbox for FI clients.
🇪🇪EstoniaCONDITIONAL: Estonian required UNLESS client explicitly consents to English.Finantsinspektsioon (via KFN, April 2026)★★★Add language consent checkbox for EE clients.
🇱🇹LithuaniaCONDITIONAL: Lithuanian required for customer service and complaints.Lietuvos bankas (15.05.2026)★★★Provide complaints process in Lithuanian.
🇸🇮SloveniaCONDITIONAL: Slovenian required for complaints handling.AZN (May 2026)★★★Provide complaints process in Slovenian.

Verified by EU National Regulators

Direct confirmations from EU national supervisory authorities — April–May 2026.

🇸🇮

AZN

Slovenia

May 2026
“All elements listed in your Compliance Interpretation Matrix and Additional Framework Questions except one can be considered confirmed.”

No client signature required. Checkbox + payment = valid consent.

★★★
🇭🇷

HANFA

Croatia

May 2026
“We have not identified any inconsistencies with the legal framework in the Republic of Croatia.”

Full online model confirmed.

★★★
🇱🇹

Lietuvos bankas

Lithuania

15.05.2026

Ref: 2026/S12-2396 — signed with QES by Director Vaidas Cibas

“Your interpretation can be considered confirmed.”

All matrix elements confirmed.

★★★
🇫🇮

FIN-FSA

Finland

March 2025

General Good memorandum

No client signature required. Language requirement: Finnish/Swedish or explicit client consent to English.

★★★
🇨🇿

CNB

Czech Republic

April 2026

§2758(2) Civil Code: payment = written form fulfilled. No broker mandate needed. Insurance Distribution Act §96 confirmed as supervisory scope.

★★★
🇧🇪

FSMA

Belgium

May 2026
“Home Member State is exclusive contact for all matters relating to passporting.”

Host NCA has no jurisdiction over contract form.

★★★
🇪🇪

Finantsinspektsioon

Estonia

April 2026

Via FSC Bulgaria

General Good provisions: no client signature required. Language: Estonian or explicit consent. AML: MLTFPA applies.

★★★
🇸🇪

Finansinspektionen

Sweden

May 2026

General Good Rules PDF (25 pages)

No language requirement. No client signature requirement. Dienstverleningsdocument not required. Remuneration must be disclosed.

★★★
🇳🇱

AFM

Netherlands

May 2026

General Good Rules PDF

Provisieverbod does NOT apply to MTPL/CASCO/Travel. Dienstverleningsdocument (Dutch) required before purchase.

★★★

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. 2023/2673/EUDistance Selling Directive (DSD)

    Applies from 19 June 2026 across all 27 EU member states. Replaces Dir. 2002/65/EC and amends Consumer Rights Dir. 2011/83/EU. Mandates a 14-day right of withdrawal for distance-concluded insurance contracts, an online withdrawal button (symmetry with conclusion), refund within 30 days, and a confirmation on a durable medium. Travel insurance under 1 month is exempt. Direct effect — applies even where national transposition is missing.

  • 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, Distance Selling Dir. 2023/2673/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

Do I have the right to cancel an insurance policy purchased online in the EU?
Yes. Under Directive 2023/2673/EU (Distance Selling Directive), from 19 June 2026 all consumers in the EU have a 14-day right of withdrawal from online insurance contracts. The insurer or broker must provide an online withdrawal function that is as easy to use as the conclusion flow. Travel insurance with cover under 1 month is exempt. MTPL withdrawal leaves the vehicle uninsured — a replacement policy must be purchased immediately.
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 remains mandatory under Bulgarian law (ZDP). A bill to remove it was voted on in the National Assembly in July 2025 but did not pass; there is no confirmed removal date.
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.
Do I need to provide insurance documents in the local language in every EU country?
No — in 20 of 27 EU member states, English is accepted for insurance documents with client consent. Mandatory local language requirements exist in France (French, Loi Toubon), Belgium (by region: Dutch in Flanders, French in Wallonia, both in Brussels), and Luxembourg (French or German). Conditional requirements (local language for complaints only, or unless the client explicitly consents to English) apply in Finland, Estonia, Lithuania, and Slovenia. Source: national regulator responses, April–May 2026.

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Research published April 2026