FSMA Clarifies Permitted Activities for Registered Insurance Intermediaries in Belgium

Key Takeaways

• The Belgian Financial Services and Markets Authority (FSMA) has published a newsletter article clarifying that registration as an insurance intermediary permits mediation in insurance products and the provision of financial planning services.
• Compliance teams should confirm that any non-insurance offerings to clients stay within this perimeter to avoid unauthorized activity.

Deep Dive

The Belgian Financial Services and Markets Authority (FSMA) has published a newsletter article clarifying that registration as an insurance intermediary permits mediation in insurance products and the provision of financial planning services. Compliance teams should confirm that any non-insurance offerings to clients stay within this perimeter to avoid unauthorized activity.

On financial planning, the FSMA indicates that intermediaries may advise on optimizing the structure of a client's assets, and on their planning, protection, legal structuring, or transfer. This advice must be based on the needs and objectives the client has indicated. The needs-based condition is the key safeguard. Firms should be able to show that advice is tied to documented client objectives rather than to product-sales targets. The press release is high level, and the detailed guidance sits in the full newsletter, which is available only in French and Dutch.

No deadlines or new obligations are introduced. This is a clarification of the existing perimeter rather than a rule change. Even so, it signals supervisory attention to intermediaries that expand into adjacent services. Firms that sell investment, banking, or other regulated products without the proper status risk enforcement, sanctions, and possible consumer redress claims.

Recommended actions for compliance professionals:
- Obtain and review the full newsletter, using qualified French or Dutch translation where needed.
- Map all products and services currently offered by intermediaries, including tied agents and sub-brokers, against the permitted scope.
- Check that financial planning advice is supported by documented client needs and objectives.
- Update policies, training, and client disclosures to reflect the permitted scope.
- Escalate any out-of-scope activity for legal assessment and remediation.

Overall impact is low to moderate. The greatest exposure is for intermediaries with diversified offerings or cross-selling incentives, where scope creep and conduct issues are most likely.

Source: Financial Services and Markets Authority