In summary…
Before comparing contracts, check three things about the intermediary: their registration with the’ORIAS (the official register of insurance, banking and finance intermediaries), the category under which he is listed, and how he is paid. This takes ten minutes, on a public register and in documents that he must give you.
Balmont Conseil is a firm not independent In regulatory terms: he receives commissions paid by product providers, including insurers. We state this from the first meeting, the engagement letter specifies it, and you must obtain the same transparency from any intermediary.
A Lyon-based executive, who will be moving abroad in a few months, received three offers for Luxembourg insurance contracts through three different channels. None of them disclosed who was paying the person presenting the offer. This is the first piece of information that should be requested, even before the insurer's name and the advertised return.
1. Three acronyms, three pieces of information to check
ORIAS and brokerage: registration precedes any activity
Every insurance intermediary must be registered with the single register maintained by ORIAS before commencing operations. The ACPR (French Prudential Control and Resolution Authority) does not grant licenses to intermediaries; it supervises them. Among the categories, the insurance broker (COA) is mandated by their client and is not bound by an exclusivity agreement with any insurer; the general agent is bound to a company by an exclusivity obligation; the insurance agent acts for one or more companies. Since April 1, 2022, brokers have been required to join a professional association approved by the ACPR to register.
The required guarantees are verifiable: professional competence, professional liability insurance of at least €1,500,000 per claim and €2,000,000 per year, and a financial guarantee to reimburse funds collected on behalf of clients, amounting to at least €115,000 and two months of average monthly revenue. Request the certificates.
CIF: the status that governs investment advice
The financial investment advisor (CIF) is also registered with ORIAS and belongs to a professional association approved by the AMF (French Financial Markets Authority). They must not present themselves as "approved by the AMF": the AMF does not approve CIFs, it approves their association. Upon establishing a client relationship, they provide a document indicating their identity, status, ORIAS number, association membership, and, if applicable, any business relationships with financial institutions, followed by a letter of assignment signed in duplicate, specifying the service and its remuneration.
| Acronym | What it is | What you check |
|---|---|---|
| ORIAS | Single register of intermediaries in insurance, banking and finance | Registration number, exact categories, and date of registration on the ORIAS website |
| COA | Insurance broker, mandated by the client, without imposed exclusivity. | That it is indeed included in this category; professional association; civil liability; financial guarantee |
| CIF | Financial investment adviser (CIF) | Association approved by the AMF; client onboarding document; engagement letter |
Specifically. Our ORIAS registration number is 13003497: check it in the register, just as you would for any intermediary. If the category "insurance broker" is not listed, the person offering you a contract cannot present themselves as a broker.
2. Remuneration: by you, by the insurer, or by both
Fees, commissions, or both: what the AMF figures show
An intermediary can charge fees for his advice, or to be paid by a commission The insurer pays the commission back to the policyholder from the contract fees, or a combination of both. The commission does not appear on any invoice; it is included in the entry or management fees you pay. Hence the obligation to provide information.
The key figures for investment firms published by the AMF for 2024 provide a general idea: among firms classified in the wealth management advisory segment, 60% of revenue came from commissions on entry and exit fees, 28% from commissions on management fees, and 12% from professional fees. In terms of status, 81% of firms provide non-independent advice, 7% exclusively independent advice, and 12% both.
Not independent This does not imply either a defect or a favor. According to the AMF (French Financial Markets Authority), a non-independent advisor may be remunerated by the institution managing the product; in return, they must improve the quality of their service, for example, by regularly monitoring the suitability of the investment. An independent advisor, on the other hand, offers a sufficient and diversified range of investments and must not be remunerated by the product's institution; any fees they receive from third parties must be passed on to the client. Our firm is not independent and receives commissions paid by insurers and other product providers.
For the technician. Monetary and Financial Code, Article L. 541-8-1 (conduct rules for investment advisors, whether independent or not); AMF General Regulation, Articles 325-5 (client onboarding document) and 325-6 (engagement letter), Article 325-16 referring to Articles 314-13 to 314-17 for non-independent advice, Articles 314-18 to 314-20 for the prohibition of retaining third-party benefits in independent advice; AMF position DOC-2006-23, questions 4.2, 4.4 and 6.3. In insurance: Insurance Code, Article L. 521-2 (client information, broker mandated by their client); Directive (EU) 2016/97 on insurance distribution, Article 17 (act honestly, fairly and professionally, in the best interests of the client) and Article 19, paragraph 1, point d (inform the client, before the conclusion of the contract, of the nature of the remuneration received under the contract).
3. Access to contracts: ask for the level of advice, not the number of insurers.
«We have access to numerous contracts» says nothing about the advice given. The ACPR framework distinguishes three levels. Level 1, mandatory: a contract consistent with your requirements and needs, specified in writing, along with the reasons for the recommendation. Level 2, optional: a contract selected after a comparative analysis of offers, based on these needs. Level 3, optional: a recommendation based on an impartial analysis of a sufficient number of contracts available on the market. An intermediary must be able to tell you which level they operate at and which Luxembourg insurers they have a distribution agreement with.
A Luxembourg insurer markets its services in France either through the freedom to provide services or via a branch (functioning): the intermediary remains subject to French advisory rules. As of July 1, 2025, according to the Luxembourg Insurance Commission, 27 Luxembourg assurance-vie companies were operating in France under the freedom to provide services, with 5 per establishment; this figure does not indicate how many of them employ a given intermediary. The protection of savings, however, is verified on a contract-by-contract basis (role of the CAA, depository bank).
4. Ten questions to ask before signing
- What is your ORIAS number and under which categories are you registered?
- Are you a broker (mandated by me) or an agent of an insurer?
- Is your advice independent or not independent in the regulatory sense?
- Who pays you for my case, and what amount in euros, the first year and then each year?
- At what level of consulting do you work, and with which Luxembourg insurers do you have an agreement?
- Which authority oversees the proposed insurer, and which bank holds the assets?
- What guarantees do you have: professional liability insurance, financial guarantee?
- What documents will you give me before I sign: information note, key information document, draft contract with a sample waiver letter?
- Who follows me after subscription, and how often?
- What happens if I change countries: do you continue to manage the contract?
Subscription opens a 30-day cancellation period from the date of contract conclusion. See the conditions of withdrawal and the documents to be received before committing any money.
Our position
An intermediary doesn't have to be beyond reproach in every respect; they must be transparent in three areas: their status, their remuneration, and their advice, all in writing. If one of these answers is rejected, you don't have to continue. The written answer to question 4 is sufficient to distinguish between two similar proposals.
Frequently asked questions
How can I verify that a broker is properly registered?
On the ORIAS website, you can search by name or number: the register indicates the categories (insurance broker, financial investment advisor, etc.) and the professional association. Brokerage activity without registration is illegal.
Is a commission-based consultant less reliable than a fee-based consultant?
Nothing more, nothing less: both models are permitted. The difference lies in the source of payment, and therefore the information you must request. A non-independent advisor must disclose their compensation and improve the quality of their service, particularly through follow-up.
What document proves the method of remuneration?
The engagement letter, signed in duplicate before any advice is given, specifies the remuneration of the financial advisor. For insurance, the nature of the remuneration received under the contract is among the information that the intermediary must provide before the conclusion of the contract (Directive (EU) 2016/97, Article 19).
Are you comparing Luxembourg contract proposals?
Send us the proposal: the first interview focuses on the intermediary's status, remuneration and level of advice, before the product.
Are you a notary, chartered accountant, lawyer, or fellow consultant? And a client asks you to validate a assurance-vie proposal? We can review it jointly: the client remains yours.
Book an appointment
The initial consultation is to establish your exact situation and determine if there is anything that can be done—sometimes there is nothing, and we will say so as well. Thirty minutes, with no obligation.
Book an exchange with Balmont Conseil
Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 23/10/2026.
Official sources consulted
- ACPR — Insurance intermediaries (categories, ORIAS, capacity, civil liability, financial guarantee)
- ACPR — Principles of insurance advice (July 2018)
- AMF — Guide «Financial Investment Advisors (FIAs)»
- AMF — Position DOC-2006-23, questions and answers on the CIF regime
- AMF — Key figures for financial investment advisors 2024
- Service-Public.fr — Assurance-vie contract: subscription (fact sheet F15268)
- EUR-Lex — Directive (EU) 2016/97 on insurance distribution
- Insurance Commission (Luxembourg) — Annual Report 2024-2025, annexes, tables 2.7 and 2.8
