By Yair Knijn · June 4, 2025

IDD made the broker responsible for the add-on cover they bolted onto the fleet policy

The account manager who places a fleet program is the most exposed person in the room and rarely knows it. The renewal came up, the carrier had a tidy gap-cover add-on, and bolting it across every vehicle on the schedule looked like a clean upsell. Product governance? That was the insurer's product, so it was the insurer's problem. That assumption is wrong, and a regulator can prove it with two questions: who is the target market for this cover, and what were you paid to sell it.

The trap is that the broker treated distribution as a pass-through. Under the Insurance Distribution Directive, it never was.

What IDD product oversight and governance obliges distributors to do, not just carriers

The IDD, in force across the EU since 1 October 2018, splits product responsibility in two. The manufacturer (usually the carrier) designs the product, defines a target market, and runs the product approval process. That part lives in Commission Delegated Regulation (EU) 2017/2358. The half brokers skip is the distributor half: you have to obtain the manufacturer's product information, understand the defined target market, and arrange a distribution strategy that stays inside it. If you sell outside the target market, you are obliged to tell the manufacturer, and the regulation expects that feedback loop to run on a periodic basis, not when a claim blows up.

Bolting an add-on across a fleet is a distribution decision. You made it. The POG duty attaches to you the moment you do.

Fleet add-ons as the classic target-market mismatch

A fleet is not one risk, it is forty risks that happen to share a payer. The gap-cover add-on that fits a three-year-old leased van does very little for a vehicle the customer owns outright and depreciated to nothing, and it can be plainly unsuitable for a unit that is already covered under a finance agreement. Bundle one rate across the whole schedule and you have sold cover the target market documentation never described to a chunk of vehicles it was never meant for.

The honest version is per-vehicle. Before the add-on goes on a unit, the broker should be able to answer:

• Does this vehicle's ownership and value actually sit inside the cover's stated target market?
• Is the customer already carrying equivalent protection through lease or finance terms?
• Would a careful adviser put this specific car in this product, or is it riding along because the rest of the fleet did?

Remuneration disclosure: the second IDD trap most brokers under-document

The first question a regulator asks is suitability. The second is money. The IDD requires pre-contractual disclosure of the nature and basis of your remuneration, and whether it is a fee, a commission, or something else. An add-on with a fatter commission than the base motor cover is exactly the conflict the disclosure rule exists to surface. If the add-on earned you more and the file does not show the customer was told the basis of that, the bundle reads as a product sold to pay the broker, not to fit the risk. That is the inference you do not want a supervisor drawing, and a thin file invites it.

Building a POG and disclosure trail into fleet placement

None of this requires heroics. It requires a record that survives the question. For every fleet placement, the broker should hold the manufacturer's target-market statement, a per-vehicle note of why each unit fits the add-on or was left off it, the remuneration basis disclosed to the customer, and a log of anything sold outside the target market so the periodic feedback to the carrier writes itself. The failure mode is never the absence of judgement. It is the absence of evidence that judgement happened, six months later, when the schedule has already drifted and nobody remembers the call.

That trail is easier to hold when the fleet program is one live record rather than a binder and three inboxes. FleetLedger keeps each customer's fleet program as a single reconciled source, so the target-market fit, the add-on decision, and the remuneration disclosure sit against the vehicles they apply to and stay there when the regulator asks. See how it works.