Global FinTech Guide
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InsurTech is composed of the words “insurance” and “technology”. It is used as a collective term for the application of modern technologies in the domain of insurance services.

Digital and mobile brokers: FinTechs belonging to this category mostly act as digital insurance brokers and provide users with an overview of their insurance contracts with their respective conditions. Some FinTechs offer very short-term insurance contracts to cover specific cases which can be concluded often spontaneously via mobile devices. Oftentimes additional consulting services are offered.

Internet of things: FinTechs belonging to this category collect data by measuring for example the driving style of the customers or through wearables the customers wear to consult on, offer and/or manage the customer’s insurances.


Attitude of the country towards InsurTech-services

Portugal has been affirming itself as a country that is friendly to technological innovation, so there is no institutional or civil society resistance to the development of InsurTech.

The Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF) – the Portuguese Insurance Regulator – has already formally expressed its support for technological innovation. The regulator says that it is present in several initiatives, organisations, and events, in order to accompany the technological evolution in the financial area in general and specifically in the scope of insurance and pension funds.

On the other hand, and within the scope of its supervisory powers, it also adds that the ASF has an active role in the digital ecosystem, balancing benefits and risks for the consumer and the market, within a balanced regulatory framework that allows it to provide a high level of consumer protection without unnecessary barriers to innovation.

In short, we can say that concerns are lawful and only relate to matters such as data protection or consumer rights.

Finally, the "Portugal FinLab" is one (1) of the most relevant InsurTech initiatives in Portugal, providing direct contact between innovators and regulators. This is a platform where the ASF directly monitors the progress of InsurTechs, actively contributing to the identification of regulatory issues linked to the start-ups' or incumbent institutions' business models.

Moreover, ASF is perfectly aligned with the European initiatives to promote FinTech, namely under the European Commission's Financial Technology Action Plan which, since 2018, outlines the guidelines for a more competitive and innovative financial sector.

Legal affairs

Obligations and requirements to provide InsurTech-services

The costs and requirements under consideration are the same for all insurance companies, and there is no discrimination between their status as InsurTech or as traditional companies. Indeed, InsurTech designation is not a legally attributable status. It is based merely on a finding of fact about their business and operating model. Therefore, the foundation of Insurance Law in Portugal is made up of three (3) diplomas:

  • Law no. 147/2015, of 9 September, which approved the legal regime for access to and exercise of insurance and reinsurance activity;
  • Decree-Law no. 72/2008, of 16 April, which approved the legal framework of the insurance contract; and
  • Law no. 7/2019, of 16 January, which approved the legal framework for insurance and reinsurance distribution.  
Law no. 147/2015 provides that a person or legal entity that is established in Portugal may not, in principle, carry out any life or non-life business without first receiving the authorisation of the Portuguese regulator, the ASF. The ASF will, on application, grant authorisation if the applicant demonstrates that, inter alia, will comply with several provisions regarding the company's management, employees, finances, and structure. 

Decree-Law no. 72/2008, of April 16, provides the main regulation for the insurance and reinsurance sector in Portugal. It is a diploma that provides the general rules on insurance contracts and typifies the contractual regimes applicable to the most economically and socially relevant insurances, such as health, car, or life insurance.  

Law no. 7/2019 of 16 January (Insurance Distribution Law), on its turn, approves the legal framework on insurance and reinsurance distribution, transposing Directive (EU) 2016/97, known as the Insurance Distribution Directive. It establishes a uniform legislative framework applicable to the different participants, insurance intermediaries, ancillary or otherwise, and insurance undertakings, directly involved in the distribution activity, regardless of the channel used. Insurance intermediaries are now qualified under the following categories: insurance agent, insurance broker and ancillary insurance intermediary.

Finally, and without prejudice to the other existing payment mechanisms, insurance companies are obliged to pay 0.048% of the revenue regarding direct life insurance and 0.242% of the revenue regarding direct insurance of the other branches in supervisory fees, as indicated in Ordinance no.74-B/2016, of 24 March.  

Insurance intermediaries are subject to payments between EUR 50 and EUR 400 per year, depending on their turnover, also due to the above-mentioned Ordinance.  

Additional comments regarding the legal situation for InsurTech-services or what InsurTech’s must be aware of in this business area


Economic conditions

Market size for InsurTech-services and biggest companies in this business area

Seventeen-per-cent (17%) of the Portuguese FinTech market is held by InsurTechs. This is a very expressive number, only preceded by the payments and money transfers sector with 27% of the market share.

Notwithstanding the other InsurTechs that may be mentioned, we can highlight the following as the largest Portuguese InsurTechs: habit, Keep Warranty, Kooli, lovys, and mudey. These are Portuguese InsurTechs with distinguished business models.

Habit is a technology provider and insurance distribution platform that bridges non-insurance brands and companies with insurers and re-insurers in order to sell insurance policies. On the other hand, Keep Warranty offers a 100% digital channel to sell and buy life and non-life insurances. Kooli, for its part, has developed a platform allowing to manage the entire health insurance benefits. In this sense, Lovys offers customised and fully digital insurance products through an all-in-one monthly subscription (or separately), to a whole range of tailor-made insurance: home, car, mortgage, smartphone, pets etc. Finally, Mudey provides an intelligent all-in-one platform to buy and manage insurance. 

Although there are no official or estimated figures for the aggregate profits of the InsurTech sector in Portugal, it is possible to say that the largest Portuguese FinTechs raised € 437 million in capital, and from August to December 2021, more than € 820 million was raised in a total of 115 investment rounds according to the Portuguese FinTech House 2021 report.

Additional comments regarding the economic situation for InsurTech-services or what InsurTech’s must be aware of in this business area




© 2022, Abreu Advogados. All rights reserved by Abreu Advogados as author and the owner of the copyright in this chapter. Abreu Advogados has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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