Choice of Law for Insurance Contracts: History of Article 7 of Rome I, Particularly Regarding the Relationship with Directives 88/357 and 90/619 in Light of Directive 2009/138

Abstract

Article 7 of Rome I contains the same rules on choice of law for insurance contracts as previously found in various insurance directives. The rules are technically very complicated. They may be explained as a compromise between Member States wanting to protect their own insurance industry from cross-border competition, and Member States more eager to provide export opportunities for their insurance providers.

Keywords

• Rome I
• insurance contracts
• choice of law
• principles of free movement
• RomeI
• insurancecontracts