White-Label-Versicherungen: Mehr Transparenz für Versicherte

The draft restates and sharpens existing expectations rather than creating new law: policyholders must be able to identify, without ambiguity, which insurer actually bears the risk, and insurers must satisfy their pre-contractual information duties and the transparency and truthfulness principle across all distribution materials. For compliance teams, the practical exposure sits in the distribution chain rather than in the product itself. White-label products are designed by the risk carrier but marketed under a partner's brand — typically banks, brokers, comparison platforms or affinity groups — so the insurer retains regulatory accountability for how its identity is disclosed at every customer touchpoint.

Firms should expect scrutiny of partner-facing documentation, co-branded marketing approvals, digital journeys and post-sale communications, not just the policy wording. Recommended actions: map every white-label arrangement to its disclosure path; audit partner marketing collateral and online journeys for clarity on insurer identity; refresh product oversight and governance approvals to evidence partner sign-off; tighten contractual clauses obliging distributors to use approved wording; and prepare a consultation response where the requirements are ambiguous or operationally costly. Risk concentrates in reputational damage, consumer-protection findings and remediation costs for large distribution networks; opportunity lies in differentiated, clearer customer communications and stronger partner governance as a competitive differentiator.