All workers count toward the “fewer than three persons” threshold, including part-time staff, contractors, owners, and self-employed workers. Employment status doesn’t matter.
Article 17 of Regulation (EU) 2019/2088 exempts insurance intermediaries which provide insurance advice with regard to IBIPs and investment firms which provide investment advice that are enterprises irrespective of their legal form, including natural persons and self-employed persons, provided that they employ fewer than three persons. As there is no definition of “employ” or “employee” in Regulation (EU) 2019/208, how are self-employed staff, owner managers or part-time employees counted?
The headcount in Article 17 of Regulation (EU) 2019/2088 applies regardless of the features of the employment relationship, i.e. part or full-time.
European Commission
