France: brokers and general agents — the ORIAS register, mandatory associations and the ACPR's focus

The French market is interesting because the state has delegated part of the oversight of brokers to professional associations, while the supervisory authority ACPR is increasingly active in regulating the quality of advice.

Who operates in the market

All intermediaries are entered in the single ORIAS register. The main categories in insurance are:

• brokers (courtiers);
• general agents (agents généraux), who work under an insurer's mandate;
• insurance representatives (mandataires d’assurance);
• intermediaries' sub-agents (mandataires d’intermédiaires).

According to the ORIAS annual report, as of 31 December 2025 the register contained 72,666 intermediaries and 123,083 entries (one company may hold several statuses). Of these:

• 27,500 brokers (+2.0% year on year);
• 12,035 general agents (+1.3%), for whom insurers declared 35,929 active mandates;
• 30,949 intermediaries' sub-agents;
• 3,593 insurance representatives.

The 2022 brokerage reform

Law No. 2021-402 of 8 April 2021 required brokers and their sub-agents to join a professional association accredited by the ACPR. The rule has applied since 1 April 2022, with certain exceptions. A broker who has not joined an association is not re-registered with ORIAS and drops out of the register.

An association performs several functions:

• it checks whether a member meets the conditions for access to the profession and the professional requirements;
• it provides mediation;
• it supports its members and collects market statistics.

The ACPR accredits associations and may withdraw their accreditation.

The Lemoine Law: borrower insurance

Law No. 2022-270 of 28 February 2022 (the "Lemoine Law") allowed borrowers to cancel and replace their mortgage loan insurance at any time. For new loans this right has applied since 1 June 2022, and for previously concluded contracts since September 2022.

Since 1 June 2022, insurers have also been prohibited from requesting a medical questionnaire if the insured portion of the loans does not exceed EUR 200,000 per insured person and the loan is repaid before that person's 60th birthday.

For agents and brokers, the law opened the borrower insurance market to competition: a client can be won over at any point during the life of the loan, but can be lost just as easily.

ACPR focus in 2025–2026

On 31 December 2025, the revised ACPR recommendation 2024-R-03 on the duty to advise began to apply. Its key provisions:

• the client must be advised throughout the entire term of a life insurance contract, as well as property and personal insurance contracts;
• when selling a new policy, it must be checked whether the client is already insured against the same risk;
• particular caution is required if the client surrenders an old life insurance policy in favour of a new one: the benefit of the replacement must be justified;
• the client's sustainable investment preferences must be ascertained.

In its 2026 work programme, published on 19 January, the ACPR pledges to continue monitoring the risks of certain products and sales practices. The regulator will continue its work on value for money and its discussion with the market on including management fees for life insurance contracts in the national assessment system. Oversight of outsourced functions and of insurers' work with intermediaries and delegated partners is singled out separately.