The Legal Framework of InsurTech Compliance in Georgia
Digital channels have changed how insurance is distributed, but the legal perimeter of the insurance market remains the same: intermediation is carried out by insurance agents and insurance brokers, supervision belongs to the State Supervisory Service, and insurance activity begins only with a licence. Under Article 12 of the Law of Georgia on Insurance, intermediary activity in the insurance sphere is carried out by insurance agents and insurance brokers; an insurer may carry on insurance activity both directly and through agents and brokers, but is obliged to carry it out only through a duly registered insurance broker. It follows that an insurtech platform operating as a distribution channel cannot escape the intermediation framework — the only question is under which status and against which requirements it operates. The same article draws the boundary of what is not intermediation: the supply of additional information to a consumer within the frame of another professional activity, where its purpose is not to assist in concluding or performing an insurance contract, does not count. That boundary matters for platforms performing a purely informational function without participating in distribution.
Intermediary Status and the Registry
The formal marks of broker status are set directly by law. A person carrying on the activity of an insurance broker must have a firm name containing the words "insurance broker", and the use of those words without registration is prohibited. The registration of insurance brokers — and its cancellation — is carried out by the Service, which maintains the registry of insurance brokers, including an electronic one; data on registration, amendments to registration data or deregistration are entered in the registry within 2 business days of the decision and are published in the Legislative Herald within 10 days of the decision. For a platform this means that every change in its intermediary function also requires an update of its registration data — a compliance point that is easily missed when the product iterates faster than the paperwork.
Consumer Protection — Article 20-1
A digital channel does not dilute consumer-protection duties — it sharpens the supervisory focus. Under the first part of Article 20-1, the insurer and the insurance intermediary must ensure the protection of consumers' rights at every stage of the pre-contractual relationship, the operation of the contract and the full performance of the obligations provided by the contract, in accordance with the Insurance Law and the Law on Protection of Consumers' Rights. The Service is authorized to supervise the performance of these obligations, to issue legal acts, give written instructions and impose additional requirements and restrictions; it may request and process information about the applicant and other consumers, including personal data. The consumer, for their part, has a choice: where the insurer or agent fails to perform obligations, the consumer may apply to the insurer's relevant structural unit, the court or any other authorized public or private institution — and where their rights are violated, also to the Service; the same logic applies against a broker. Building the complaint route into the product journey is therefore not just good practice but a statutory expectation.
Supervision and Licensing — Articles 21 and 22
The Service's powers are broad: issuing and revoking licences, registering brokers, supervising compliance with normative and methodological requirements, inspecting accounting documents, applying sanctions, maintaining registries, and defining the types and minimum amounts of capital, insurance reserves, the solvency margin and reporting forms, as well as requesting information on direct and beneficial owners. The licensing requirements are equally precise: an insurance licence is granted only to a legal person in the organizational-legal form of a joint-stock company, and only for three activities — life insurance, insurance and reinsurance; the authority to grant life-duration annuities belongs only to an insurer holding a life insurance licence. Reinsurance may be conducted within an existing licence where the insurer notifies the Service in writing within 10 business days of starting the activity. An applicant submits constituent documents, bank confirmations of the full monetary payment of capital, identification documentation for significant shareholders and administrators, information on the origin of capital, and a business plan for the 3 years following the start of insurance activity.
Frequently Asked Questions
Can insurance be distributed online without intermediary status?
No. Intermediation is carried out under agent or broker status, and a broker must be registered with the Service.
How quickly are broker registration changes reflected?
In the registry — within 2 business days of the decision; publication in the Legislative Herald follows within 10 days.
What form must an insurer take?
Only a joint-stock company; the licence covers life insurance, insurance and reinsurance.
Where does a consumer apply on a rights violation?
To the insurer's structural unit, the court, any authorized institution — and to the Service.
How We Help on Legal.ge
InsurTech compliance means fitting the business model onto the rules of intermediation, consumer protection and licensing. On Legal.ge you can engage an insurance-law specialist who will assess your platform's regulatory status, plan the registration or licensing and protect your interests with the supervisor. Submit a request on the site and get qualified assistance.