For most car insurance contracts, switching at the end of the year is possible, and the cancellation letter has to reach the insurer by November 30 (Verbraucherzentrale). For insurance brokers, that means weeks full of first conversations — on the phone, by email and through the inquiry form on the website. Every one of these conversations triggers the same duty: at the first business contact, the client receives the initial disclosure under Section 15 VersVermV, the German Insurance Mediation Ordinance. It states who you are, the status under which you are listed in the intermediary register, how you are paid and which dispute resolution body the client can turn to. The obvious move is to put this text on the website. What is easy to overlook is that the ordinance treats paper as the default and accepts a website without a client login only under four conditions. This article explains the twelve items, the conditions for the website route, the difference from the imprint and a setup made of a dedicated page, a footer link and a consent field in the form. Real estate agents work under different rules; their property listings are covered in a separate article on estate agent websites.
Why the initial disclosure matters in switching season
The consumer advice center Verbraucherzentrale sums up the deadline briefly: the letter must reach the insurer by November 30. The notice period is usually one month (Verbraucherzentrale). In 2026, November 30 falls on a Monday.
Anyone who wants to switch therefore compares offers in October and November, requests quotes and often talks to a broker for the first time. That is exactly the moment Section 15(1) VersVermV refers to: the trader has to provide the policyholder with the prescribed information “at the first business contact” (VersVermV). What counts is not the signature on an application but the start of the business relationship — before it is even clear whether a contract will be concluded. For an inquiry through the website, the first reply is the natural point to provide it. Phone calls follow a rule of their own, covered further below.
The group concerned is large. As of January 1, 2026, the intermediary register listed 46,951 insurance brokers licensed under Section 34d(1) GewO, out of a total of 178,791 registrations of insurance intermediaries and advisers (DIHK). The initial disclosure is not a broker-only duty either: Section 15(1) no. 3 VersVermV explicitly distinguishes between brokers, agents with their own license, tied agents, ancillary intermediaries and insurance advisers. Nor does it stop with the owner. Under Section 15(2) VersVermV, the trader has to ensure that his employees also meet the disclosure duties that apply to him (VersVermV). For an office with two or three staff, this means that whoever answers the phone or replies to inquiries in November needs to know how the initial disclosure reaches the client — before the first client who wants to switch calls.
The deadline does not apply to every contract
The twelve items under Section 15 VersVermV
Section 15(1) VersVermV lists in twelve numbered items what the client has to learn at the first business contact (VersVermV).
Some of them are quick to write, others require a deliberate decision by the office, such as the type of remuneration or whether advice is offered at all. The list below follows the order of the ordinance, shortened and tailored to a broker. The wording of the ordinance remains authoritative; anyone using a ready-made template should compare it with this list before it goes on the website.
- Surname and first name, and for commercial partnerships also the firms in which you act as managing partner
- Your business address
- Your status, for example insurance broker licensed under Section 34d(1) GewO, your entry in the intermediary register and how that entry can be verified
- Whether you offer advice
- The type of remuneration you receive in connection with the mediation
- Whether the remuneration is paid directly by the client or is included in the insurance premium as commission or other remuneration
- Whether you receive other benefits as remuneration
- Whether your remuneration is a combination of these types
- Address, phone number and web address of the joint office under Section 11a(1) GewO, plus your registration number
- Your holdings of more than 10 percent of the voting rights or capital of an insurance company (VersVermV)
- Insurance companies or their parent companies that hold more than 10 percent of the voting rights or capital of your office (VersVermV)
- The address of the dispute resolution body that can be called on in disputes between intermediaries and policyholders
Four items deserve particular care on a broker website. For the status (item 3), the exact designation matters: under Section 34d(1) GewO, anyone who gives the client the impression of acting as an insurance broker is also deemed to be one (GewO). A tied agent whose website talks about independent broker advice therefore risks being treated as a broker — without the matching license. For remuneration (items 5 to 8), a general sentence is not enough; the client should be able to see whether he pays a fee, whether the commission is included in the premium or whether both apply. The joint office (item 9) is the German Chamber of Commerce and Industry, whose contact details are listed in the imprint of the intermediary register (Vermittlerregister). And for the dispute resolution body (item 12), Section 214 VVG helps: the Federal Office of Justice can recognize bodies for disputes between intermediaries and policyholders (VVG); the Versicherungsombudsmann e. V. is recognized as such a body (Versicherungsombudsmann). If a client turns to it, the broker is obliged under Section 17(4) VersVermV to take part in the dispute resolution procedure (VersVermV).
Paper is the default
How the information reaches the client is governed by Section 16 VersVermV.
Section 16(1) sets four requirements: on paper, in a clear, accurate and comprehensible manner, in an official language of the member state in which the risk is situated or another agreed language, and free of charge (VersVermV). Paper is therefore not one option among several but the starting point. Paragraph 2 allows two deviations. The first is a durable medium other than paper, if that is appropriate in the context of the business and the client was able to choose between paper and the durable medium and chose the latter. The second is a website — either with personalized access for the client or, without a client login, only if four conditions are all met. The table shows the routes side by side.
Scroll table sideways
| Route | Requirement under Section 16 VersVermV | What it means in practice |
|---|---|---|
| Paper | The default under paragraph 1 number 1 | Printed initial disclosure at the meeting or by mail |
| Durable medium | Appropriate and chosen by the client after a choice between paper and durable medium (paragraph 2 number 1) | For example a PDF file the client can save, after the client’s explicit choice |
| Website with client login | Personalized access for the client (paragraph 2 number 2 letter a) | Client portal in which the initial disclosure is stored |
| Website without client login | Appropriate, consent, location sent electronically, available for as long as needed (paragraph 2 number 2 letter b) | Dedicated page, consent field in the form and link in the first reply email |
| First contact by phone | Information under paragraph 1 or 2 immediately after the first contact (paragraph 4) | Paper or email with link right after the call |
Two additions belong in every plan. First, speed matters for phone contacts: under Section 16(4) VersVermV, the information has to be provided immediately after the first business contact, on paper or through one of the routes in paragraph 2 (VersVermV). Anyone taking many calls in November needs a fixed routine for this, for example an email with the link right after the call, provided the client has agreed to the website route. Second, Section 16 largely follows the wording of Article 23 of Directive (EU) 2016/97 on insurance distribution, the IDD. The directive additionally provides that the client is to receive a paper copy free of charge on request if the information was provided on another durable medium or via a website (IDD). Offering on the disclosure page to send the text by mail on request covers this point as well.
Four conditions for the website route
For broker websites without a client portal, Section 16(2) no. 2 letter b VersVermV is the decisive provision. The four conditions are joined by “and”: if one is missing, paper or the durable medium remains the route (VersVermV).
What the provision does not say matters too. A link in the imprint, an “Initial disclosure” entry in the footer or a paragraph on the home page does not meet all four conditions on its own. These create the location and can secure ongoing availability, but they do not replace the client’s consent or the electronic notification sent to him. The page on the web is therefore a prerequisite, not the fulfillment.
- Appropriate: providing the information via a website suits the business. Under Section 16(3), this is the case in particular when the client provides an email address for the purposes of this business, for example in the inquiry form.
- Consent: the client has agreed to receive the information via a website. A dedicated consent field in the form makes that agreement visible.
- Location sent electronically: the client has received the website address and the exact location of the information electronically, for example as a link in the first reply email.
- Available: the information remains accessible for as long as the client can reasonably need it. A fixed address and a maintained version are part of that.
In practice, the four points translate into a short routine. The inquiry form asks for the email address and contains an optional field with which the client agrees to receive the initial disclosure via the website. The first reply names the link to the page with the initial disclosure. The page itself sits at an address that does not change and states the date from which its text applies. If consent is missing — because someone does not tick the box or because the contact began on the phone — paper or a durable medium of the client’s choice remains the route. This two-track approach is not a flaw of the website route but exactly what Section 16 provides for. That is also why the field should not be mandatory: whoever does not agree simply receives the initial disclosure on paper.
The sentence for the first reply email
Imprint and initial disclosure are two different pages
The initial disclosure is easily confused with the imprint because the details overlap.
The imprint follows Section 5(1) of the German Digital Services Act (DDG): name and address, ways to make quick electronic contact including the email address, details of the competent supervisory authority for activities that require official authorization, and the commercial register or a similar register with the registration number. An insurance broker needs a license from the competent Chamber of Commerce and Industry (GewO) and has to be entered in the intermediary register without undue delay after starting the business (GewO). As a rule, the imprint therefore names the chamber and the intermediary register with the registration number. The imprint addresses every visitor and has to be permanently available. The initial disclosure, by contrast, is a notification to the individual client at a specific point in time, with content the imprint does not provide for, such as remuneration and holdings. Which details an imprint generally needs is covered in the article on imprint and privacy policy.
Scroll table sideways
| Item | Imprint under Section 5 DDG | Initial disclosure under Section 15 VersVermV |
|---|---|---|
| Name and address | yes, permanently available | yes, surname and first name, business address |
| Contact route with email address | included | not explicitly required |
| License and supervision | details of the competent supervisory authority | status under Section 34d GewO, for example broker with a license |
| Register and number | commercial register or similar register with number | intermediary register, registration number, how to verify the entry |
| Joint office | not part of Section 5 | address, phone number and web address |
| Remuneration and advice | not part of Section 5 | whether advice is offered, type and source of remuneration |
| Holdings | not part of Section 5 | holdings above the threshold in items 10 and 11 |
| Dispute resolution body | not part of Section 5 | address of the dispute resolution body |
This distinction matters for the setup in XICflow. XICflow creates the imprint and privacy policy before every publish if they are missing; existing pages are not overwritten in the process. The content of the imprint is generated from the website’s company details: name, authorized representative, address, phone, email, VAT ID and, for corporations, the register court and register number (XICflow documentation). The imprint page carries no blocks of its own; what appears there is changed in the base data. The company details have no field of their own for the details that only concern intermediaries — supervisory authority, intermediary register and registration number — so they do not appear in the imprint and cannot be added there by hand as a block either. Before the first client contact, go through the published imprint point by point against Section 5 DDG, and settle well before switching season how the missing intermediary details get into it. The initial disclosure itself is not generated automatically either; it needs a page of its own. How the mandatory pages come about is described in the documentation on legal pages.
Make the registration number verifiable
Setting up the initial disclosure as a page of its own
The initial disclosure belongs on a page of its own with a fixed address, such as /erstinformation/.
It lists the twelve items in the order of the ordinance, notes that the text is also available on paper on request, and shows the date of the current version. It is linked where clients look for mandatory information: in the footer next to the imprint and privacy policy. XICflow provides the “Legal texts (footer column)” setting for this, with a label and a target per entry. Your own entries replace the default list completely, so the imprint and privacy policy have to be included explicitly (XICflow documentation). If your footer is built from blocks, add the page as an additional link in the “Legal links” block; the derived legal pages remain in place there. The settings are described in the brand and design documentation. Which job the footer does in the page network, and which a text link does, is explained in the article on internal links.
- Create a page of its own called “Initial disclosure” (Erstinformation) at a fixed address
- List the twelve items in the order of Section 15(1) VersVermV, with the registration number and a reference to vermittlerregister.info
- Name the remuneration specifically: commission in the premium, fee or both
- Give the dispute resolution body with its address
- Add the version date and the offer of a paper copy
- Link the page in the “Legal texts” footer column next to the imprint and privacy policy
- Do not set the page back to draft: a draft is not delivered at all
The fourth condition — the information remains available for as long as the client can reasonably need it — is a question of operations, not of the first publish. Three properties help here. If you rename a page, XICflow remembers the old path and redirects it permanently to the new address, so a link from a November reply email still reaches its target after a rename. A page set to draft, by contrast, is not delivered at all — anyone who sets the initial disclosure to draft for editing takes it offline for that time. And every publish leaves a version in the “Version history” with time and person (XICflow documentation), so it can be traced later which version was online when. The documentation describes the version history. Who may change the page is a matter of roles and a well-protected account; the article on passkeys, two-factor authentication and sessions covers that.
Collecting consent in the inquiry form
For consent under Section 16(2) no. 2 letter b, item bb VersVermV, the “Form” block in XICflow offers the “consent” field type.
You set the label and whether it is mandatory yourself; in the request, the field appears as “Ja” or “Nein”, and extra fields later show up under their own label in the request and in a separate column of the export (XICflow documentation). Keep this consent separate from the notice on data processing: one concerns the delivery route of the initial disclosure, the other data protection. The email field covers the standard case of appropriateness at the same time, because under Section 16(3) VersVermV the website route is appropriate in particular when the client provides an email address for the purposes of this business (VersVermV). What short, well-labeled forms look like is shown in the article on contact forms; the field types are listed in the requests documentation.
Field type: Consent (not mandatory)
Label: I agree that you provide the initial disclosure under
Section 15 VersVermV to me via your website.
In the request: [label] - Ja
First reply email, second paragraph:
Our initial disclosure under Section 15 VersVermV is available at
https://www.your-broker-office.example/erstinformation/
On request, we will also send it to you on paper.Three more points belong in the season plan. First, consent can only be shown for as long as the request is stored: by default, XICflow keeps requests for 180 days and then deletes them for good (XICflow documentation). Anyone who needs the record for longer saves it via the CSV export or forwards the request, including all custom form fields, by webhook to their management software; the article on forwarding by webhook describes that route. Second, the initial disclosure does not replace advice: under Section 61 VVG, the reasons for any advice have to be given and documented, and under Section 62 VVG this documentation generally goes to the client in text form before the contract is concluded (VVG). Third, switching bonuses do not work as a lure on the car insurance page. Special benefits are prohibited for intermediaries; only rewards or gifts up to a total value of 15 euros per insurance relationship and calendar year count as minor (VAG).
Checklist before November 30
- Check your status in the intermediary register and copy the registration number exactly as it appears there
- Publish the “Initial disclosure” page with the twelve items, a version date and the offer of a paper copy
- Link the page in the “Legal texts” footer column next to the imprint and privacy policy
- Check the published imprint against Section 5 DDG, in particular supervisory authority and register
- Add an optional field of the “consent” type for the website route to the inquiry form
- Store the sentence with the link to the initial disclosure as a template for the first reply email
- Decide who sends the initial disclosure right after a phone call — on paper, or by link after consent
- Review the car insurance page for switching bonuses and blanket deadline promises