SUSEP advances in regulating Open Insurance

The regulation aims to expand the possibilities of society and market participation in the structuring of operating models within Open Insurance. As defined in CNSP Resolution No. 415, of 2021, the Initiating Companies, as mandatory participants in Open Insurance, must be accredited by SUSEP and incorporated as a corporation. In the implemented model, insurers will be able to carry out some activities offered by SISS and set up a company with the specific purpose of carrying out these service initiation activities.

Insurance brokers and brokers will also be able to establish commercial partnerships with the SISS, aimed at providing gains in efficiency and agility both in contracting operations and in meeting consumer demands throughout the entire life cycle of the products. In addition, the possibility of forming or transforming themselves into initiators is preserved, if they meet the requirements of capital and cyber security, among others established in the resolution.

The movement initiation service provided by SISS is intended for the customer's experience and must be ordered by the customer. This includes the initiation of procedures related to taking out insurance, an open supplementary pension plan or capitalization certificate, endorsement, redemption or portability of a pension or capitalization plan, payment of a drawing, claim notice, among others.

The Initiating Companies must have financial requirements such as shareholders' equity greater than BRL 1,000,000.00, follow governance rules, data, and information confidentiality, in addition to cyber security, similar to those required for insurance companies and subject to the General Law of Data Protection, as well as complying with specific conduct requirements aimed at ensuring the proper treatment of customers.

The rule establishes sanctions and penalties for cases of non-compliance with the Open Insurance rules by SISS, with the provision of fines that can reach BRL 1,000,000.00.

In the Open environment, all insurance companies that wish to can present their prices based on information authorised by the client, which will be able to rely on data brought from the Open Finance integrated platform.