25/03/2025
Harju County Court upheld the decision of Finantsinspektsioon to fine IIZI Kindlustusmaakler AS 24,000 euros for a misdemeanour. The company breached the prohibition on transferring the marketing of insurance, the duty for the intermediary to act in the insurance interests of the client, and the requirements set by law.
The Insurance Activities Act states that an insurance intermediary may not transfer the marketing of insurance. The insurance intermediary also has an obligation to act in the interests of the client and to act within the requirements set by law, with its due diligence corresponding to the level of complexity of the insurance contract, and with the foresight and competence expected of the intermediary. IIZI Kindlustusmaakler AS broke the terms of the law prohibiting the transfer of marketing and endangered the interests of clients, and so it committed a misdemeanour under § 261 (2) of the Insurance Activities Act and must pay a fine of 24,000 euros. The maximum fine for a legal entity for such an offence at the time it was committed was 32,000 euros, but now the fine for such an act could be up to 400,000 euros.
IIZI Kindlustusmaakler AS appealed the Finantsinspektsioon decision of 3 June to the Harju County Court. On 28 November the court confirmed that the decision of Finantsinspektsioon was correct and appropriate, and that the company had to pay the fine and the costs of the defence. IIZI Kindlustusmaakler AS may dispute the decision as allowed by law. IIZI Kindlustusmaakler AS lodged an appeal in cassation against the judgment of Harju County Court. By its judgment of 12 June 2025, the Supreme Court annulled the decision of Finantsinspektsioon in the misdemeanour case and terminated the misdemeanour proceedings due to the expiry of the limitation period. The Supreme Court did not take a position on the substantive issues of the misdemeanour case, nor did it provide any further guidance on the interpretation of the prohibition on outsourcing insurance distribution laid down in the Insurance Activities Act.
The judgment of the Supreme Court is available on the Supreme Court’s website.
Updated 25 August 2026