IDD demands and needs statement

Category: Group risk regulation · Reviewed by Mark Fox, Broker · Renewals · Last reviewed 2026-06-10

The IDD demands and needs statement is the customer-facing document required under Article 20 of the Insurance Distribution Directive (transposed into UK law via ICOBS 5 of the FCA Handbook). The statement must identify the customer’s demands and needs, explain the basis on which the contract has been recommended, and confirm that the proposed contract is consistent with those demands and needs. Where regulated advice is provided, the statement must also explain the basis of the advice.

Category: Group risk regulation Also known as: D&N statement Statutory basis: IDD Art. 20; ICOBS 5 Related concepts: ICOBS 5 product information, ICOBS Insurance Conduct of Business Sourcebook, FCA Handbook insurance distribution

Definition

The statement is not merely a confirmation slip; it is a substantive deliverable. Best practice is to produce a tailored statement for each customer addressing (i) the demands and needs identified through the discovery process; (ii) the contract proposed and how it meets those demands and needs; (iii) any limitations or known mismatches; and (iv) the basis on which advice (if given) has been provided.

Legal / Regulatory basis

Article 20 IDD; ICOBS 5.2 and 5.3. The statement must be produced in writing on a durable medium. For digital distribution, the statement may be delivered electronically (subject to consumer durability requirements). The statement may be standardised by product (for example, motor or home), but for group risk and protection products it is normally customer-specific.

Scope of cover

The statement applies to all distribution of non-investment insurance with limited modifications for large risks. For group risk distribution to a commercial customer, the statement may consolidate the demands and needs analysis of multiple products (group life, GIP, group CI, group PMI) into a single coordinated document.

Practical example

A group risk broker produces a six-page demands and needs statement for an employer client covering (i) the rationale for the GIP cover — protect employee income on long-term sickness, reduce risk to the employer of unfunded long-term sick pay, support recruitment and retention; (ii) the GIP product proposed — 60% of salary, 26-week deferred, 5-year limited payment; (iii) the alternatives considered and rejected; (iv) the price and remuneration; (v) the basis of advice. The customer signs the statement.

See also

References

  1. Directive (EU) 2016/97, Art. 20 — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016L0097
  2. Financial Conduct Authority, FCA Handbook, ICOBS 5 — https://www.handbook.fca.org.uk/handbook/ICOBS/5/
  3. Financial Conduct Authority, PS18/1 — IDD Implementation

This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-10. Next review: 2026-12-10.

Apex Insurance Brokers Limited. Authorised and regulated by the Financial Conduct Authority, FRN 724952. Registered in England and Wales, Companies House 07014570. This entry provides general information about UK insurance concepts and is not regulated advice. Consult your insurance broker on your specific position.

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