IDD 15 hours: using the time to practice the duty of advice

The 15-hour IDD training is the obligation on insurance distributors to train for at least fifteen hours a year. In France it is set out in Article R. 512-13-1 of the Insurance Code (Code des assurances), which transposes Directive (EU) 2016/97, the Insurance Distribution Directive (IDD), which matters to US insurers and brokers operating in the EU. Short answer: the hours are mandatory. Their content and format are up to you, and the duty of advice is the best use to make of them.

This article recalls what the text says. It explains why hours of e-learning are not enough to produce good advice. Finally, it proposes a method for devoting part of the volume to role-plays on needs analysis.

What does the 15-hour IDD training obligation provide?

Article R. 512-13-1 of the French Insurance Code, in force since February 23, 2019, sets three main rules.

• A minimum number of hours. The time devoted to professional training or development, referred to in II of Article L. 511-2, cannot be less than fifteen hours per year.
• Flexible arrangements. Training can take place in person or remotely, in one or several sessions. It can be delivered by a training provider, an insurer or reinsurer, an intermediary, a credit institution or a finance company.
• A competence objective. The training must allow the skills needed for the functions held to be regularly updated.

The text also specifies that all or part of these hours can count toward a certification listed in the national register, in category A. An order of the minister in charge of the economy sets the list of skills covered.

What evidence must be kept?

Insurers and intermediaries must be able to produce the list of training followed. The text asks for the name of the organization, the date, the duration, the format and the topics covered. This is the list the supervisor can request.

An attendance sheet or a completion certificate meets the requirement for a record. It does not say whether the distributor is more competent. Our article on proof of training and the audit trail shows what a practice debrief adds as evidence.

Why the duty of advice deserves part of the hours

The duty of advice is the moment when the distributor's competence shows. Article L. 521-4 of the Insurance Code sets out this duty. The distributor gathers the customer's requirements and needs, recommends a suitable policy and explains in writing the reasons for the recommendation. The ACPR, the French prudential supervisor, published a recommendation on the duty of advice in November 2024, available on its website.

Yet the difficulty is not knowing the obligation. It is conducting the interview. You must ask the right questions in the right order, listen, rephrase and resist the urge to sell the product already in mind. These skills are built in conversation.

An e-learning module presents the steps of needs analysis. It does not make you handle a customer in a hurry who answers “just give me the cheapest”. Nor does it deal with the one who refuses to give their family situation. These are everyday cases.

How to conduct the needs analysis, step by step

Here is an outline the trainer can turn into a role-play scenario.

1. Frame the interview. “Before suggesting anything, I am going to ask a few questions to understand your situation.”
2. Explore the situation. Occupation, family, assets to protect, existing policies, budget. One open question, then follow-ups.
3. Draw out expectations. “What would be the most troublesome for you in the event of a claim?”
4. Rephrase. “If I sum up, you want to protect your family and keep a stable premium. Is that right?”
5. Recommend and justify. “I recommend this option, for these two reasons linked to what you told me.”
6. Point out the limits. “This policy does not cover such and such a case. Would you like us to look at a complementary option?”
7. Record. The needs expressed and the reasons for the recommendation are put in writing.

Each step has its trap. At step 2, the advisor skips questions because the customer is in a hurry. At step 4, they rephrase what they wanted to hear. At step 5, they justify by the product rather than by the need.

The difficult situations to practice

The fifteen hours leave room for specific cases. Here are the ones that come up most.

• The customer who only wants the price. The advisor must recall what a low price covers, without moralizing.
• The customer who refuses to answer. “I understand there are a lot of questions. They let me offer you suitable cover.”
• Selling a policy under a sales quota. The advisor knows a given product earns more. They must resist, or flag the conflict.
• The customer who discovers an exclusion after a claim. The difficult conversation is about what was explained at the start.
• The customer already insured elsewhere. The advisor must explore possible overlap of cover before offering a new policy.

Trainers who know their agency network pick these situations from real complaints, rather than from a generic catalog. The scenario then gains credibility: the learner recognizes their own customers, their products and their objections.

Why e-learning alone cannot carry the 15 hours

Fifteen hours of modules followed alone, at your own pace, fill the training record. They depend heavily on motivation, often low when the content repeats from one year to the next. Experienced distributors finish them while looking for the “next” button.

This phenomenon is not specific to insurance. Our page on mandatory compliance training shows how it is found in every obligation. The article on fatigue with annual regulatory training offers levers to vary formats without losing the record.

The text leaves exactly this freedom: in person or remote, one or several sessions. Nothing prevents devoting several hours to practice sessions, provided that topics, durations and formats are recorded.

Devoting part of the hours to role-play

One possible split, to be adjusted with compliance, distinguishes three phases. The first, of about five hours, is devoted to updating knowledge: products, regulation, developments. The second, of about eight hours, is devoted to advice role-plays spread across the year. The third, of about two hours, is used for feedback on complaints and the action plan.

These figures are an example of organization, not a rule of the text. The only legal minimum is fifteen hours per year. What matters is that each practice session is debriefed and recorded.

With Face Up, the trainer builds the scenario themselves from their cases. The learner speaks, by voice or on video, with a persona played by an AI. It could be a customer in a hurry who wants the lowest price. The debrief indicates the objectives met or not, the strengths and the points to improve. It proposes an action plan and quotes what was said. The learner replays to improve.

Building the annual training plan over fifteen hours

An effective plan starts from functions and not from the catalog. A branch customer manager, a broker and a claims adjuster do not perform the same tasks. The text itself speaks of the skills needed for the functions held.

Here is a simple four-step approach.

1. Identify the gaps. Analyse complaints, disputed files and internal control remarks. They show where advice is deteriorating.
2. Choose the situations. Pick three or four typical conversations per job.
3. Spread through the year. One practice session per quarter avoids the “December rush” effect in December.
4. Measure and adjust. Compare the first and second sessions: has the wording of the questions improved?

This plan is documented in the same register as other training. For each practice session, note the organization or trainer, the date, the duration, the format and the topic. These items directly answer the list the text requires you to be able to produce.

Frequently asked questions

Do the 15 IDD hours apply to all of an insurer's employees?

Article R. 512-13-1 is linked to Article L. 511-2. The exact scope depends on your status, your functions and your organization. Your compliance department will confirm the populations concerned.

Can the 15 hours be done all at once?

Yes. The text allows one or several sessions, consecutive or not. Spreading them through the year does, however, help retention and allows situations to be replayed after feedback.

Is online training enough?

The text allows it, since training can be done remotely. It must nevertheless update the skills needed for the functions performed. For advice, a share of conversational practice meets that objective better.

If you want to turn part of your IDD hours into advice role-plays, book a demo and start from a real complaint. You can also look at AML training (the French LCB-FT regime) and GDPR training, which follow the same logic.