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Paris121 bis, rue de la Pompe, 75116 Paris, France

Luxembourg30, rue Marie-Adélaïde, L-2128 Luxembourg

Distribution and partnerships

We draft agreements between insurers, brokers, independent wealth advisers and banks, and check that each network, face-to-face or online, complies with insurance distribution rules.

France

A distribution chain divides obligations between several parties: the insurer designs the product, the wholesale broker manages its sub-brokers, the distributor advises the client, a service provider administers the contracts.

When this division is not written down, or not applied, a failure to advise, contracts presented by an unauthorised person or disputed remuneration can make several links in the chain liable at once. We draft the agreements, operating procedures and control procedures that make this division clear and verifiable.

What we do

01 Design

Distribution agreements and operating procedures

  • Framework distribution agreements between insurers, brokers and co-brokers.
  • Brokerage, sub-brokerage and co-brokerage agreements; the relationship between wholesale broker and sub-broker.
  • Operating procedures and guides between insurers, brokers and service providers.
  • Partnership agreements with banks (⁠) and asset management companies.
    BancassuranceThe distribution of insurance contracts through bank networks.
  • Coordinating channels: territorial exclusivity of agents, independent brokers, mutual sector networks.
  • ⁠: independence of the subscribing association, presentation by the subscriber, commission.
    Group insurance contractA contract taken out by a legal entity (an association, an employer, a bank) that individuals join as members.
  • Affinity insurance contracts, including personal cover linked to travel.
02 Design

Online subscription and distance selling

  • Adapting contracts and pre-contractual information to distance selling, including the rules on distance marketing of financial services revised by an Ordinance of 5 January 2026, applicable since 19 June 2026.
  • Subscription journeys: providing and downloading information, proof that it was provided, expression of consent, electronic signature, immediate start of cover.
  • Evidence agreements with policyholders, other parties involved and certification service providers.
  • Online management: switches, use of a ⁠, limits on switches under self-directed management, information on how the contract evolves.
    Discretionary management mandateA way of managing a unit-linked contract in which the policyholder delegates switching decisions to a mandated manager, within an agreed investment strategy.
  • Remote advice and telephone platforms: (devoir de conseil), recording of conversations.
    Duty to adviseThe obligation of the insurer or the distributor to propose a contract consistent with the client’s demands and needs, and to explain the reasons for that advice.
  • Online medical questionnaires, death cover and processing of health data, including automated processing.
  • Portals and links between websites: characterisation of the information published, rules on presenting insurance transactions, tied sales.
  • Payment methods for the initial premium and for regular premiums.
03 Steer

Delegated administration and outsourcing

  • Delegated administration agreements between insurers, brokers and service providers; underwriting mandates.
  • Procedures for controlling delegated activities, including between intermediaries.
  • Administration partnership agreements, in France and in other Member States.
  • Characterisation of transactions (provision of services, financial product, insurance) and the regulatory and tax consequences, notably for VAT.
04 Steer

Intermediary networks: status, compliance, remuneration

  • Status of brokers, general agents and other agents (mandataires): registration with ORIAS (the French register of insurance intermediaries), membership of an approved professional association for brokers and their agents, professional competence, good repute, continuing training.
  • Organisation of brokerage firms: corporate purpose, separation of activities, formalities, internal organisation.
  • Presentation of insurance transactions: introducers, agents, asset management companies, financial canvassing, exemptions for and group contracts.
    Borrower (creditor) insuranceInsurance that guarantees repayment of a loan if the borrower dies, becomes disabled or is unable to work.
  • Remuneration: commission flows, retrocessions between intermediaries, continued commission after termination, information for the client.
  • Preventing and managing conflicts of interest.
  • Standard advice and warning wording, adapted to each contract and to the requirements of the (IDD).
    Insurance Distribution Directive (IDD)Directive (EU) 2016/97 on insurance distribution, transposed in France in 2018. It governs the information, advice and remuneration of distributors. In French: directive sur la distribution d’assurances (DDA).
  • Compliance of distribution agreements and advertising materials with the recommendations of the (the French prudential supervision and resolution authority).
    ACPRAutorité de contrôle prudentiel et de résolution: the French authority, attached to the Banque de France, that authorises and supervises banks and insurers and oversees the protection of their customers.
  • Legal and tax audit of networks.
05 Steer

Foreign intermediaries and cross-border distribution

  • Intermediaries established in another Member State operating in France under the (FOS) or the (FOE).
    Freedom to provide services (FOS)The regime under which an insurer authorised in one State of the European Economic Area can cover commitments located in another Member State without being established there, on the basis of its home-State authorisation (the European passport). In French: libre prestation de services (LPS).
    Freedom of establishment (FOE)The regime under which an insurer from one State of the European Economic Area can operate in another Member State through a branch. In French: liberté d’établissement (LE).
  • Legal and tax audit of the conditions under which they operate.
  • Agreements with local intermediaries for French insurers distributing in another Member State.
  • Distance-selling arrangements in several Member States, set up with lawyers from those States.
06 Defend

Distribution disputes

  • Civil liability of intermediaries: advice, warnings, information, breaches of contract.
  • Commissions and retrocessions between insurers and intermediaries, or between wholesale brokers and sub-brokers; clawback of upfront commissions after cancellation.
  • Disputes arising from brokerage, sub-brokerage, delegated administration and service agreements.
  • Contracts presented by persons not authorised to do so.
  • Intermediary fraud in the distribution chain: misappropriation, forgery, deception; audit, crisis management, settlements, criminal complaints and civil actions.
  • ACPR inspections of a distribution network and their follow-up.

Examples of matters

  1. 01

    Legal audit of distribution networks and assistance in setting them up, including for online sales.

Frequently asked questions

Does a CGP (independent wealth adviser) distributing life insurance contracts have to join a professional association?

In principle, yes, if the acts as a broker or as a broker’s agent. Since 1 April 2022 (Act of 8 April 2021), registration of these intermediaries with ORIAS requires membership of an ACPR-approved professional association, which checks in particular their good repute, professional competence, liability insurance and continuing training. General agents and insurance agents are not subject to this requirement.

Independent wealth adviser (CGP)An independent professional who advises clients on their wealth and who distributes, among other things, life insurance contracts as an intermediary. In French: conseiller en gestion de patrimoine (CGP).

Can a life insurance contract be taken out entirely online?

Yes. Distance selling requires providing pre-contractual information on a durable medium before the contract is concluded, obtaining consent and keeping proof of it, for example by electronic signature, and observing the thirty-day (renonciation) specific to ⁠. The duty to advise also applies online: demands and needs collected, reasoned advice. An Ordinance of 5 January 2026, applicable since 19 June 2026, revised the distance marketing rules.

Life insuranceA contract under which an insurer undertakes to pay a lump sum or an annuity, at the end of the agreed term or on the death of the insured person, in return for premiums. In France, it is also widely used as a savings and wealth transfer vehicle.
Right of cancellation (renonciation)The right of the holder of a life insurance or capitalisation contract to withdraw from it within thirty days of being informed that it has been concluded. If the information documents required by law were not provided, this period is extended, for a holder acting in good faith, up to a limit of eight years.

Can an intermediary established in another Member State distribute in France?

Yes. Registered in its home Member State, it notifies that State’s authority of its intention to operate in France, under the freedom to provide services or through a branch; that authority informs the French authorities, and the intermediary then appears on the ORIAS register. It remains subject to French general good rules, particularly on client information and advice. Its agreements with French insurers and distributors must take this into account.