Insurance web aggregation is an alternative distribution channel whereby a customer can obtain insurance through the internet or mobile application. Insurance web aggregators are internet-based platforms that provide insurance policy quotations from various insurers based on pre-determined set of needs provided by clients.
Section 50 of the lnsurance Code, as amended, allows the policy to be in electronic form subject to the Electronic Commerce Act and to such regulations as may be prescribed by the Insurance Commissioner. Pursuant thereto, the Insurance Commission (“IC”) promulgated the Guidelines on Electronic Commerce of Insurance Products in 2014, providing a uniform framework on online solicitation of insurance products by industry players, putting online selling of insurance products within the supervision and regulation of the IC. Such framework includes minimum requirements regarding information that must appear in the insurance provider’s website, the proper language used on such website, the reasonable steps to be undertaken with respect to contract formation and execution online, measures to ensure compliance with data privacy and other applicable laws, security of payment, complaint handling and/or dispute resolution, and unsolicited email.
To further fulfill its mandate of safeguarding consumers with respect to insurance products sold or solicited online, the IC has set new rules for the regulation and supervision of insurance web aggregators or the so-called “price comparison websites”. Based on IC Circular Letter 2018-51, the objective is to supervise and monitor insurance web aggregators as an insurance intermediary that maintains a website for providing insurance prospect with price comparison and information on products sold by different insurers.
For the grant of licence/renewal, which shall be valid for 3 years from the grant or renewal, the said circular letter requires the applicant to fulfill and submit the following:
With regard to item (e) above, the online aggregators and insurance companies must incorporate in their agreement several provisions laid out in the circular letter, as follows:
Insurance Commissioner Dennis Funa said that the IC recognises the increasing number of insurance comparison websites and the important role they play in boosting the online market for insurance products. Thus, the IC recognises the need to regulate these platforms to ensure that both the insuring public and the insurance industry are protected.
This alert is for general information only and is not a substitute for legal advice.