AFM publishes report on online steering towards embedded insurance

In July 2026, the Netherlands Authority for the Financial Markets (AFM) published the report “‘Do you want to add insurance?’ - online steering towards embedded insurance” (Report), which contains an exploratory study of the online choice environment of platforms that offer embedded insurance. 

This Regulatory Alert discusses the Report’s key observations and recommendations.

Embedded insurance

Embedded insurance refers to insurance that is offered during the sale of another type of product or service by (online) non-financial platforms or shops. For example, insurance may appear as an additional choice during the purchase of a plane ticket, festival ticket or television. The AFM’s Report follows up on its November 2025 study on the opportunities and risks of embedded insurance (see the Regulatory Alert on the findings and recommendations from that earlier study here).

In the recent Report, the AFM assessed the presence of steering elements in the choice environment of platforms that offer embedded insurance and the associated risks to consumers. These findings are divided into three sections:

• how is the insurance offered (choice structure)?
• what information does the consumer receive (choice information)?
• what other triggers are used (choice pressure)?

Choice structure: how is the insurance offered?

The AFM notes that many platforms prominently highlight the possibility of taking out insurance during the process of purchasing a product or service. On many platforms, consumers are drawn to the possibility of taking out insurance at multiple stages. Because insurance is offered prominently and repeatedly during the customer journey, the estimated need for this product can become distorted. When making the insurance choice, the choice to insure is often shown much more prominently than the choice not to insure, and all platforms offer a limited number of insurances. Due to unbalanced presentation of insurance and non-insurance and the lack of comparison options, consumers are steered towards the insurance offered. In addition, on most platforms taking out insurance is a low-friction process, which can contribute to more consumers taking out insurance and taking less time to do so.

Choice information: what information does the consumer receive?

According to the AFM, most platforms present information about insurance in layers, but the information in the top layer is usually limited. Pages and documents with more extensive product information are difficult to access and understand on many platforms, which means that the current provision of information increases the chance that consumers will make choices based on an incomplete and one-sided picture. Moreover, there is little clarity about overlaps with existing insurance policies and about the total premium or the monthly cost of the insurance. This can lead to consumers making uninformed decisions.

Choice pressure: what triggers are used?

In addition to the way information about insurance products is shared and the content of this information, the AFM sees additional forms of influence. Platforms steer consumers towards taking out insurance by using text that taps into consumer sensitivities, such as loss aversion and social proof. Platforms use reassuring wording for this purpose and may mention the number of customers who purchased a specific insurance policy in the past period. Platforms also use visual techniques that present the insurance products in a more visually striking and positive way through colours, icons and images, while the non-insurance option is accompanied by warning icons and images with examples of damage. Finally, some platforms have limited reservation time for the purchase of the product or service, which means the decision of taking out insurance must be made under time pressure. This encourages consumers to make quick decisions about the insurance and increases the likelihood that they will make an uninformed choice.

Conclusion and recommendations

The AFM sees that the online choice environment of platforms with embedded insurance often contains multiple elements that steer consumers towards taking out insurance during their purchase. The degree of steering in the online choice environment does not seem proportionate to the extent to which these products are suitable for consumers and the provision of information within the choice environment is often insufficient to enable consumers to make an informed decision. In addition, the AFM emphasises that providers and/or platforms must comply with the requirements regarding the provision of information, product distribution and unfair commercial practices when designing the choice environment. The AFM calls on platforms and providers that offer embedded insurance to design their online choice environment carefully. For this purpose, the AFM has made the following recommendations:

• Provide clear, complete and accessible cost information: Present costs transparently and clearly, provide key information in an understandable way and at the right time within the customer journey, make additional documentation easily accessible and clearly state whether the cover offered may overlap with existing insurance policies or warranties.
• Provide a balanced presentation of options: Present insurance options and the choice not to insure in an equal and clear manner and make clear that taking out insurance is not a mandatory or standard choice.
• Use low-friction carefully: Make the option not to insure as simple as the option to insure, design the choice environment in such a way that the decision requires a conscious consideration by consumers and set up the process in such a way that explicit agreement is requested for conditions and additional obligations.
• Limit the use of steering elements: Use behavioural triggers, such as social influence or time pressure, with restraint and only when they support careful consideration by consumers.

The Report can be consulted here.

Contact

For more information on the AFM Report and how it could impact your business, contact your CMS client partner or the CMS experts who contributed to this article.