BRUSSELS—The Comité Européen des Assurances says any changes to E.U. rules on insurance broking should take into account the diversity of national market systems.

The rules also should be appropriate for the size and complexity of the brokerage or distribution channel that is being regulated, the CEA said Monday in responding to the European Commission’s consultation on the E.U. Insurance Mediation Directive.

The CEA, which represents insurers and reinsurers in Europe, said if the European Commission requires more transparency concerning broker pay, “an appropriate solution would be to ensure that the customer is informed up front about the form and source of the intermediary’s remuneration.”

In its response to the consultation, which ended Monday, the CEA proposed six general principles to govern the sale of insurance: ensuring that the buyer is treated fairly, intermediaries offering advice where needed or requested, always informing customers about the type of service being performed on their behalf, basing any advice given on an analysis of the buyer’s needs, distributors understanding the product they are selling, and the buyers being able make an informed choice about the insurance product before a contract is concluded.

The European Commission launched a review of the Insurance Mediation Directive in November.

The directive, which was adopted in 2002 and had to be transposed into the national laws of the E.U. member states by January 2005, is intended to protect consumers and provide buyers with sufficient information about the insurance they are being sold.

While a minimum level of consumer protection has been achieved across Europe since the directive was introduced, the European Commission said it launched the latest public comment period because a “patchwork” of national regulations had emerged across the European Union.

In addition, the commission said it wanted to review the directive in the light of Solvency II, the risk-based capital regulatory regime for insurers and reinsurers in Europe that is slated for introduction in 2012, and to revise it “in order to extend the benefits of a risk-based solvency regime and increased transparency rules to policyholders.”

The commission will consider the responses to its consultation.