# Professional indemnity for intermediaries in Germany: meet the licence, close the gaps > Anyone who arranges insurance, investments or residential mortgages in Germany needs professional indemnity cover for financial loss to get the trade licence. In German it is called Vermögensschadenhaftpflicht, or VSH. It pays when a client loses money because of advice or arranging errors, and defends unfounded claims. The statutory minimum gets you registered; the quality lies in the activity wording, run-off cover and exclusions. Quelle/Source: https://www.nammert.com/en/insurance-broker-intermediary-professional-indemnity.php Updated: 2026-11-13 ## Is professional indemnity compulsory for intermediaries in Germany? Yes, for everyone who needs a licence under § 34d (insurance intermediaries and insurance advisers), § 34f (investment intermediaries), § 34h (fee-based investment advisers) or § 34i GewO (mortgage credit intermediaries). Without proof to the Chamber of Commerce (IHK) there is no licence and no register entry. Tied agents whose insurer accepts liability for them are exempt. For insurance intermediaries the minimum has been EUR 1,564,610 per claim since 9 October 2024. ## At a glance - **Compulsory?:** Yes, for licences under § 34d, § 34f, § 34h and § 34i GewO - **Minimum § 34d:** EUR 1,564,610 per claim, EUR 2,315,610 per year (since 9 October 2024) - **Minimum § 34f and § 34h:** EUR 1,276,000 per claim, EUR 1,919,000 per year (§ 9 FinVermV) - **Minimum § 34i:** EUR 460,000 per claim, EUR 750,000 per year (§ 10 ImmVermV) - **Typical premium:** brokers about EUR 800 to 1,200 a year plus insurance tax, according to an IHK ## Each licence comes with its own minimum sum The amounts derive from EU law and rise every five years in line with the European consumer price index. For insurance intermediaries and advisers, Delegated Regulation (EU) 2024/896 set the minimum at EUR 1,564,610 per claim and EUR 2,315,610 for all claims in a year from 9 October 2024. Older policies with EUR 1,300,380 no longer meet the requirement. Investment intermediaries and fee-based investment advisers need EUR 1,276,000 per claim and EUR 1,919,000 per year under § 9 FinVermV, whatever the scope of their licence. Mortgage credit intermediaries need EUR 460,000 and EUR 750,000 under § 10 ImmVermV. If you hold several licences, each needs matching proof, usually within one policy that lists all activities. ## What the Chamber of Commerce checks, and what it does not For the licence your insurer issues a confirmation of cover based on the IHK template, stating the minimum sums and the insured activity. Under group policies arranged through an association or a broker pool, the sums apply per insured person. If the policy ends, the insurer informs the IHK, and without new proof the licence is at risk. The confirmation says nothing about run-off cover, exclusions or the deductible beyond the statutory part. Whether a policy covers advice on closed-end funds, occupational pensions or errors from a comparison tool only shows in the policy wording. That is where offers differ. ## Breach, run-off and long limitation periods Advice errors often surface years later: the disability cover that was never in place, or the fund that did not suit the client. Most German policies are triggered by the breach, meaning the date of the error, not the date of the claim. What matters is how long after the policy ends claims can still be reported, and whether prior acts cover catches unknown errors from before the start date. This becomes critical when you switch insurers or retire. If you sell your client book or stop trading, agree run-off cover for former intermediaries. Otherwise you are uninsured for old advice while clients can still bring claims for years. ## The new § 34k licence and the limits of cover From 20 November 2026, § 34k GewO introduces a new licence for arranging consumer credit. Existing licences under § 34c expire no later than 19 November 2027. If you arrange consumer loans, check that your policy names this activity. No intermediary policy pays for guaranteed returns, embezzled client money or knowing breaches of duty. In the compulsory part the insurer often cannot raise these defences against the injured client (§ 117 VVG, the German Insurance Contract Act), but it will then recover the payment from the intermediary. ## What is covered - Financial loss suffered by clients through advice or arranging errors - Defence against unfounded claims, in court if necessary - Broker, multi-tied agent and insurance adviser activity, depending on the licence - Arranging investment funds and other investments, if included - Arranging residential mortgages, if included - Employees and freelancers in the insured activity - Errors in servicing client policies, such as missed updates or cancellations - Loss of or damage to files and documents, depending on the policy - Run-off cover after the policy ends or the business closes, depending on the policy ## What is not covered - Knowing breaches of duty and intentional damage - Promises about returns, income or performance - Embezzlement, cash shortfalls and handling of client money - Activities without the required licence or registration - Fines, penalties and punitive damages - Your own or affiliated products and companies - Bodily injury and property damage, which need office liability cover - Claims under US or Canadian law unless agreed ## Who needs it - Insurance brokers and multi-tied agents licensed under § 34d GewO - Fee-based insurance advisers - Investment intermediaries and fee-based investment advisers under § 34f and § 34h GewO - Mortgage credit intermediaries under § 34i GewO - Consumer credit intermediaries with the new § 34k GewO licence ## Who does not need it - Tied agents whose insurer accepts liability for their activity do not need their own compulsory cover ## What it costs The premium depends mainly on your activities and commission income. One German Chamber of Commerce gives EUR 800 to 1,200 a year for insurance brokers and EUR 500 to 1,200 for genuine multi-tied agents, each plus insurance premium tax. Investment and credit activities are priced as extra modules. **What drives the premium:** - Licences and activities, especially investments beyond regulated funds - Commission and fee income in the last year - Number of people giving advice - Sum insured above the statutory minimum and deductible - Run-off, prior acts and optional modules - Claims and notified circumstances in recent years _The figures come from a Chamber of Commerce publication and apply to simple policies. Your premium is only fixed in the quote we obtain based on your licences and income._ ## The policy levels on the market - **Statutory minimum:** Exactly the legal minimum for one licence, short run-off, narrow activity wording. Enough for the register, but leaves gaps when you take over or sell a client book. - **Intermediary package:** Sums above the minimum, several licences in one policy, employees and sub-agents included, longer run-off. The right approach for most broker firms. - **Bespoke policy:** High sums, reinstatement, full prior acts, employee dishonesty as own loss and data protection liability. For larger firms, pools and firms that handle claims themselves. ## How to recognise a good policy | Criterion | Minimum standard | Strong policy | Why it matters | | --- | --- | --- | --- | | Sum insured | statutory minimum for each licence | well above it, with a separate annual aggregate per licence | One error on a large pension or commercial policy can use up the statutory sum quickly. | | Indexation to new minimums | only on request | automatic adjustment when the EU amounts rise | Otherwise the policy stops meeting the requirement after the next increase. | | Insured activities | one licence only | all licences, occupational pensions advice, policy servicing and ancillary legal services | Anything not described is not insured, even if it is part of daily work. | | Run-off cover | a few years after the policy ends | long run-off, also on retirement, sale of the business and death | Clients often report advice errors years later. | | Prior acts | none | unknown breaches before inception included | Switching insurers must not leave old advice uninsured. | | Employees and sub-agents | employees included | also freelancers and sub-agents, plus own loss from employee dishonesty | Towards the client you are liable for errors made by your people. | | Costs outside the limit | defence costs eat into the sum insured | defence costs in addition to the sum insured | Long proceedings otherwise erode the amount needed for the loss. | | Data protection and digital tools | not addressed | GDPR damages and errors from comparison tools included | Intermediaries handle health data and rely on calculators every day. | ## Insurers on the German market Professional indemnity for intermediaries is written by liability insurers and specialists, often also through framework agreements of associations and broker pools. The list shows insurers authorised for liability business in Germany, not our partners, and not every insurer covers every licence. - **Markel**: specialty insurer based in Munich, distributes only through brokers - **HDI**: part of the Talanx group, focus on commercial and professional clients - **Allianz**: German property and liability carrier of the Allianz group - **AXA**: commercial business through agents and brokers - **R+V**: insurer of the German cooperative banks - **Haftpflichtkasse**: mutual insurer specialising in liability - **Gothaer**: mutual group, sells through agents and brokers - **Zurich**: Frankfurt-based unit of the Zurich group 127 insurers supervised by BaFin, the German regulator, are licensed for this class of insurance. (Allgemeine Haftpflicht). Source: BaFin company database, 2026-09-18; EU insurers without a German office excluded. ## Typical claims and who pays - **Old disability cover cancelled too soon** (lost benefit payments, easily six figures): On the broker's advice the client cancels the old policy before the new one is accepted. A classic advice error and the core of every intermediary policy. - **Contents cover not updated after move** (reduction for underinsurance, often five figures): If the broker fails to adjust the sum after a move to a bigger home, the broker is liable for the shortfall. Servicing errors are covered. - **Fund does not fit risk profile** (investment loss and lost interest, often five figures): Covered only if investment intermediation is part of the policy. A policy for § 34d alone does not cover fund advice. - **Fixed return promised** (the gap to the promised return): Promises about income or performance are excluded in every wording. What is insured is the advice error, not the promise. - **Employee diverts client money** (the embezzled amount): Embezzlement is excluded from liability cover. Some packages add own loss from employee dishonesty, otherwise you need crime insurance. - **Health data sent to wrong person** (GDPR damages, usually four to five figures): Whether claims under Article 82 GDPR are covered differs between wordings. Strong policies name them expressly. ## Myth or truth - „The statutory minimum for insurance intermediaries never changes." ✘ False. The amounts follow inflation and are raised every five years, most recently on 9 October 2024 to EUR 1,564,610 per claim and EUR 2,315,610 per year. - „Grossly negligent advice errors are still covered." ✔ True. What is excluded is a knowing breach of duty. Overlooking something or misjudging it remains insured. - „My office liability policy also covers advice errors." ✘ False. Office liability covers bodily injury and property damage. Pure financial loss from advice and arranging is only covered by professional indemnity. - „A tied agent can work without their own PI policy." ✔ True, if the insurer they arrange for accepts liability for them. They then need neither a licence nor their own compulsory proof of cover. - „PI reimburses money an employee has stolen." ✘ False. Embezzlement and cash shortfalls are excluded. Crime or fidelity insurance covers that. ## Common mistakes - Carrying on with the old minimum sums after 9 October 2024 - Getting a new licence without adding the activity to the policy - Switching insurers and forgetting prior acts cover - Selling the client book or retiring without run-off cover - Not declaring sub-agents and freelancers - Admitting a client claim before the insurer has agreed ## FAQ ### What is the minimum sum for insurance brokers in Germany? Since 9 October 2024 at least EUR 1,564,610 per claim and EUR 2,315,610 for all claims in a year. The amounts apply to insurance intermediaries and advisers under § 34d GewO and are adjusted every five years. ### What do investment intermediaries need? Under § 9 FinVermV at least EUR 1,276,000 per claim and EUR 1,919,000 per year, whether the licence covers funds only or other investments too. The same applies to fee-based investment advisers under § 34h GewO. ### And mortgage credit intermediaries? Under § 10 ImmVermV at least EUR 460,000 per claim and EUR 750,000 per year. If you also arrange insurance, you additionally need the § 34d sums. ### Do tied agents need their own policy? Not for the licence, if the insurer they work for accepts unlimited liability for their activity. If they also arrange products from other companies or investments, the position is different. ### What happens when my policy ends? The insurer informs the IHK, and without new proof your licence can be revoked. Towards injured clients the end only takes effect after a delay (§ 117 VVG). For errors made during the policy period, the agreed run-off cover applies. ### Does PI pay if I promised a return? No. Promises about income or performance are excluded as a rule. What is insured is faulty advice, not a promise the market does not keep. ### Are my employees covered? Employees in the insured activity usually are. Freelancers and sub-agents only if the policy names them and they have been declared. If they hold their own licence, they normally need their own proof of cover. ### Do I have to report every possible error straight away? Claims must be reported promptly. Many policies also allow you to notify circumstances that could lead to a claim. That secures cover, especially just before switching insurers. ### Why use a broker for your own PI? Because the differences lie in the activity wording, run-off and exclusions, not in the statutory sum. We set your licences and actual business against the policy terms, in English if you prefer, and make sure prior acts cover leaves no gap when you switch. ## Legal basis and sources - [Insurance Contract Act (VVG, German)](https://www.gesetze-im-internet.de/vvg_2008/) - [BaFin company database (licensed insurers)](https://portal.mvp.bafin.de/database/InstInfo/) ## Request quotes We obtain quotes and come back with a comparison, free of charge. You can write in English. https://www.nammert.com/en/insurance-broker-intermediary-professional-indemnity.php#anfrage --- Your broker: Norman Nammert, trading as NAMMERT. Insurance broker licensed under section 34d(1) of the German Trade Regulation Act. Broker register no. D-C08Q-TOSD4-37. NAMMERT Assekuradeur GmbH is a separate company. It does not arrange your contract. NAMMERT Assekuradeur GmbH, Karl-Marx-Straße 4, 15711 Königs Wusterhausen, +49 3375 29 12 77, info@nammert.com. Wikidata: Q141141479.