France doesn’t have a dedicated MGA regulatory category, which creates practical difficulties for entities seeking to operate under a delegated authority model. MGAs must register as either insurance brokers (courtiers en assurances) or insurance agents (agents d’assurance) through ORIAS, the single national register for insurance intermediaries. Most MGAs choose to register as brokers, despite the fact that they functionally represent the interests of the insurer rather than the policyholder.

Registration with ORIAS is one of the fastest in Europe, typically taking only two to three weeks for a complete application. The ACPR (Autorite de Controle Prudentiel et de Resolution) provides ongoing supervision for conduct of business. The speed of ORIAS registration makes France an attractive entry point, although the lack of a dedicated MGA category means that the registration doesn’t specifically contemplate delegated underwriting. 

As an EU member state implementing the IDD, France provides full EEA passporting rights for properly registered intermediaries. This enables French-registered brokers and agents to provide services across the EEA on freedom of services and freedom of establishment bases.

There is no specific insurtech regime in France. However, the ACPR has launched an insurtech/fintech hub (pôle Fintech & Innovation), and a regulatory sandbox to assist in the development of these activities.

There is strictly no controller approval requirement, however, directors’ criminal records are checked through ORIAS, managers must demonstrate professional skills, and changes of control must be notified to ORIAS. The ACPR supervises compliance with these requirements on an ongoing basis. Changes in control may trigger notification obligations. The ORIAS registration process includes assessment of the professional competence and good repute of key individuals.

France has implemented the IDD’s POG requirements. There is growing awareness of value-for-money considerations in the French market, with regulators increasingly focused on ensuring that insurance products deliver genuine value to consumers. Commission-based remuneration is still permitted but is subject to growing scrutiny and the need to introduce a value-for-money mechanism in return for MGA remuneration.

Brokers registered with ORIAS have to maintain segregated client money accounts. Premiums collected on behalf of insurers must be held in designated trust accounts, separate from the broker’s own funds. These requirements protect policyholder funds and are actively monitored by the ACPR. Contractual arrangements between the MGA and its carrier should be reviewed carefully as MGAs that collect funds have to take out a financial guarantee that must be at least equal to EUR115,000 and may not be less than twice the average monthly amount of funds collected by the intermediary, calculated on the basis of funds collected over the last 12 months preceding the month of the date of subscription or renewal of the guaranteed commitment.

The minimum capital or professional indemnity insurance requirements for MGAs is aligned with EIOPA guidance. Brokers must also provide a financial guarantee to protect client funds. The specific financial guarantee requirements depend on the volume of premiums handled and the nature of the intermediary’s activities, see above.

The absence of a dedicated MGA classification is the most significant consideration for MGAs operating in France. This creates a structural mismatch between the regulatory framework and the operational reality of MGA businesses, which function as delegated underwriters rather than traditional brokers. Despite this limitation, France’s fast registration process, full EEA passporting and sophisticated insurance market make it a significant jurisdiction for MGA activity.