When a corporate insurer and an insurtech discuss a product partnership, the conversation usually centers on distribution: which channel, which customer segment, how fast the integration can ship. It is rarely framed around what a supervisor will want to see about that product before a single customer ever buys it.
That framing is becoming a mistake. Two regulatory developments, one from the European supervisor and one from the French one, are converging on the same target: the value a product actually delivers to the customer who buys it, and the paperwork an insurer must produce to prove it. Neither development is aimed at partnerships specifically. Both change how fast a partnership can move.
The Value for Money Question Is Now a Governance Requirement, Not a Slogan
EIOPA has been explicit about what it found when it looked closely at unit-linked and hybrid life insurance products across the European market: roughly 15% of the products it analysed raised value for money concerns, and more than half of those were marketed by fewer than 20 undertakings. The average projected return across the products reviewed, including higher-risk ones, came out at 2.6%.
EIOPA's own conclusion is worth taking at face value: this is not a structural problem with the European life insurance market. It is a concentrated problem among a minority of providers. That is precisely why it matters to everyone else. A concentrated problem invites a supervisory response calibrated to catch outliers, which means every product, including one built in partnership with a new insurtech entrant, now gets tested against the same bar.
What Product Oversight and Governance Actually Demands
The mechanism EIOPA is using is not new in name. Product Oversight and Governance, POG, has existed under the Insurance Distribution Directive for years. What has changed is how seriously it is enforced. EIOPA's supervisory statement on value for money in unit-linked products sets out three things a national supervisor now checks: that the target market for a product is defined with enough granularity to mean something, that the product has actually been tested for value for money rather than assumed to deliver it, and that costs, charges, and performance are reviewed on an ongoing basis rather than signed off once at launch.
None of that is exotic. All of it takes time, and time is the resource a product partnership is usually trying to save. A partnership that assumed POG documentation could be assembled after commercial terms were agreed is now assuming something that a supervisor is actively testing for.
ACPR Is Not Waiting for Brussels
The European layer is not the only one intensifying. The ACPR's 2026 supervisory programme includes 213 planned missions, up from 185 in 2025. That is a French-specific increase in the volume of hands-on supervisory work, layered on top of the EIOPA-level obligations rather than replacing them.
For a corporate insurer operating primarily in France, this means the compliance conversation about a new product partnership has two audiences with two different rhythms, not one. A mandate or partnership agreement written as though satisfying EIOPA's framework were sufficient is missing half the picture.
Why This Slows Down Partnerships Specifically
An insurer developing a product internally already owns its target market data, its cost structure, and its historical performance record. A partnership introduces a party that owns none of that by default. An insurtech's product economics, however well designed, have to be reconstructed into the insurer's own POG documentation before the insurer can distribute it under its own licence and its own name.
That reconstruction is the invisible cost of a partnership, and it rarely appears in the term sheet. It shows up later, as a delay between signing and launch that neither party budgeted for, and that gets blamed on "compliance" as though compliance were an external event rather than a predictable consequence of the model chosen.
The Governance Cost That Doesn't Show Up in the Term Sheet
This is the same dynamic already visible in how corporates structure venture relationships more broadly: the governance cost of a structure is rarely obvious at the moment a deal is signed, and it is almost always higher than expected once the structure has to run. A distribution partnership that must pass POG testing before launch carries a governance cost that behaves the same way.
The practical answer is not to avoid partnerships. It is to price the governance cost into the timeline from the start, the same discipline that already applies to any external investment or mandate structure, and to write it into the agreement rather than discover it during review.
What This Means for How a Mandate Gets Written
A mandate or partnership agreement negotiated today without an explicit clause on POG review timing is negotiating around a gap that a supervisor will not ignore. The boundaries of the thesis, who can say yes and how fast, and what happens if a product fails value for money testing after launch all need to be settled in writing before the first product goes live, not after the first supervisory question arrives.
Where Corporates Still Move Fast
There is one structure that avoids most of this friction entirely, at least at the pilot stage: the venture client model, where an insurer pays for a pilot without taking equity and without distributing the partner's product under its own licence. Because nothing is sold to an end customer yet, POG obligations do not attach to the pilot itself. That is precisely why this model remains the fastest entry point for testing an insurtech relationship before committing to the governance load of a full distribution partnership.
Frequently Asked Questions
Does this apply only to unit-linked products?
EIOPA's most detailed findings concern unit-linked and hybrid life insurance products specifically. The POG obligations behind them apply more broadly across the Insurance Distribution Directive, but the concentrated evidence of a problem, and the corresponding scrutiny, is strongest on this segment.
Is this a French-specific issue or a European one?
Both, and they stack. EIOPA sets the European framework and the value for money expectation. The ACPR's expanded 2026 programme adds a French-specific layer of supervisory intensity on top of it, not a substitute for it.
Does a venture client pilot avoid this entirely?
It avoids it at the pilot stage, because nothing is distributed to an end customer under the insurer's licence yet. The obligations return in full once the relationship moves from pilot to actual product distribution.
What should a partnership agreement now include because of this?
An explicit allowance for POG review time in the launch timeline, and clarity on which party owns the documentation burden if the product's target market or cost structure changes after launch.
Conclusion
Regulatory pressure on life insurance is not a temporary tightening that will ease once EIOPA's current review cycle ends. The ACPR's own numbers point the other way: more missions in 2026 than in 2025, not fewer. What determines whether a corporate insurer can still move quickly on a product partnership is not whether it can avoid this pressure, but whether it picked a structure, and wrote an agreement, that already accounts for it.
Working on this? Mandalore Partners runs corporate venture programmes for insurers and financial institutions, inclu
