The verdict in three sentences
During an inspection by the ACPR, the French insurance supervisor, a broker must show for each policy that the IDD duty to advise was met: needs collected, recommendation justified, documents delivered, all archived and dated. For a 15-person brokerage, a custom module costs, as a 2026 order of magnitude, 15,000 to 45,000 EUR excl. VAT, while full brokerage software costs 80 to 250 EUR per user per month. The right choice depends on how traceable your current tool is and on the cost of a sanction, which can reach several hundred thousand euros.
What the regulator actually checks
Since the Insurance Distribution Directive was transposed in 2018, the French Insurance Code requires distributors to record in writing the customer's demands and needs, then justify the proposed contract. During an inspection, the ACPR samples files and checks consistency between three items: the needs questionnaire, the policy signed and the written justification.
The breaches most frequently cited in published decisions are generic questionnaires identical for every client, no link between stated needs and selected cover, information documents delivered after signature, and the inability to reconstruct the history of advice.
| IDD requirement | Evidence expected in an inspection | Risk if missing |
|---|---|---|
| Demands and needs assessment | Dated questionnaire, signed or approved electronically | Breach of duty to advise |
| Justified advice | Personalised advice report linking needs and cover | Policy deemed unsuitable |
| Delivery of the product information document (IPID) | Timestamp of delivery before signature | Pre-contractual information failure |
| Remuneration disclosure | Statement of the nature of remuneration | Transparency failure |
| Product governance | Check of the product's target market | Distribution outside target |
| Continuing training | 15 hours per year per employee, certificates | Professional capacity breach |
| Archiving | Files kept for at least 5 years | Unable to prove compliance |
Market software or custom module
Brokerage software now includes an IDD workflow. Its limits often show on specialised lines (vehicle fleets, industrial risks, group protection) where the standard questionnaire does not reflect real needs. A custom module plugged into your existing tool can produce questionnaires by line of business and an automatically generated advice report.
| Option | 2026 cost (order of magnitude) | For 15 users over 3 years | Strengths | Limits |
|---|---|---|---|---|
| Entry-level brokerage software | 80 to 120 EUR per user per month | 43,200 to 64,800 EUR | Fast start | Generic questionnaires |
| Full brokerage software | 150 to 250 EUR per user per month | 81,000 to 135,000 EUR | Management, commissions, built-in IDD | Limited customisation |
| Simple custom IDD module | 15,000 to 25,000 EUR excl. VAT | 18,600 to 32,200 EUR with maintenance | Questionnaires per line | Requires an existing management tool |
| Advanced custom IDD module | 30,000 to 45,000 EUR excl. VAT | 36,000 to 55,800 EUR with maintenance | E-signature, reports, compliance dashboard | 3 to 5 month project |
| Spreadsheets and Word templates | Near zero | High time cost | No investment | Fragile audit trail |
A custom module only makes sense if your management software exposes an API or allows regular data exchange. Otherwise, migrating to full software may be the better move.
Features of a solid IDD module
An effective module covers four building blocks. First, dynamic needs questionnaires per line with conditional questions. Second, automatic generation of the advice report, which reuses the client's answers and justifies each cover retained or excluded. Third, timestamped delivery of pre-contractual documents and e-signature. Finally, a compliance dashboard: incomplete files, unsigned reports, missing training certificates.
Archiving must be tamper-proof, with a change log. An advice report modified after signature without a trace is one of the worst signals during an inspection.
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Illustrative scenario: Olivier, head of a 15-person brokerage in Lyon, handles 2,400 new policies a year. His account managers spend an average of 25 minutes per file writing the advice report in Word, that is 1,000 hours a year.
A custom module at 32,000 EUR excl. VAT, with 4,000 EUR per year of maintenance, cuts this to 8 minutes through automatic generation. It frees about 680 hours a year, valued at a loaded hourly cost of 50 EUR: 34,000 EUR. Payback is 13 to 14 months, not counting the reduced risk in case of inspection.
FAQ
How long should evidence of advice be kept?
Recommended practice is at least 5 years after the end of the relationship, longer for life or protection policies. Archives should be retrievable within 48 hours if the ACPR asks.
Is a single questionnaire for all lines enough?
No, ACPR decisions regularly criticise generic questionnaires. You need at least one questionnaire per major product family, often 5 to 10 templates for a general brokerage.
How long does a custom IDD module take to build?
Allow 8 to 12 weeks for a simple module and 3 to 5 months for an advanced version with e-signature and dashboard. A pilot on one line can ship in 6 weeks.
Is e-signature mandatory?
The IDD does not require it, but it greatly simplifies proof. A simple e-signature costs about 1 to 3 EUR per envelope with market providers, as an order of magnitude.
What sanctions does a brokerage face?
The ACPR can issue a warning, a reprimand, a ban on operating or fines that can reach several hundred thousand euros, often published by name. The reputational impact frequently exceeds the fine itself.
Let's scope your project. Tell us your lines of business, management software and policy volume: we will price the advice module, the audit trail and the timeline. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
