Commission-driven “free” advice (provisionsbasierte Beratung)

Level 3 · Advanced

German termprovisionsbasierte Beratung

Commission-driven advice is paid through remuneration connected to a product sale rather than a separate invoice from the customer. A tied intermediary may distribute for one or several named providers, while other intermediaries use wider panels. “Free advice” therefore describes the visible invoice, not the absence of compensation or incentives [1][2].

Why it matters

Commission does not prove that advice is bad, and a fee does not prove independence. The useful question is how the intermediary is paid, what product universe can be offered, what duties apply, and what happens if no sale occurs.

In Germany, a gebundener Versicherungsvertreter (tied insurance representative) is a legal status under § 34d GewO. Strukturvertrieb describes a sales structure and is not automatically the same legal category. Verify the actual register entry and the intermediary's required initial information [2][3].

Follow the incentive

Assume two products meet the stated need. Product A pays the intermediary €600 and has lower ongoing remuneration. Product B pays €1,500. The €900 difference does not establish misconduct, but it creates a question that a transparent process must answer.

Check	Evidence to request
Legal status	Vermittlerregister entry and initial status disclosure
Product range	One provider, named providers, or fair and personal market analysis
Remuneration	Fee, commission in premium, other benefit, or combination
Need analysis	Documented objectives, constraints, and reasons for the recommendation
Exit economics	Surrender value, cancellation costs, lock-up, and lost cover

EU insurance-distribution rules require disclosure of intermediary status and the nature of remuneration, and prohibit remuneration structures that conflict with the duty to act in the customer's best interests [1]. Disclosure manages a conflict; it does not erase it.

Check yourself

Why can commission-funded advice appear free to the customer?

Remuneration is connected to the product rather than shown as a separate advice invoiceNo one receives compensationThe product has no costs

Which facts help reveal a distributor's incentives? Select all that apply.

Legal status and register entryProvider rangeNature of remunerationOnly the word free in marketing

Product A pays €600 commission and Product B pays €1,500. What is the remuneration difference in euros?

Which statement is accurate?

Commission proves advice is badA fee proves complete independenceStatus, scope, remuneration, documented need, and reasons should be assessed together

Why it matters​

Follow the incentive​

Check yourself​

Sources​

Why it matters

Follow the incentive

Check yourself

Sources