Insurance intermediaries

Information video about the new regulation of insurance intermediation.

Information video about the use of the FINMA survey and application platform (EHP).

Access to the EHP for insurance intermediaries

User instructions: Registration for insurance intermediaries

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Check your intermediary activity

Check whether your activity as an insurance intermediary will be subject to the new regulation from 1 January 2024. Insurance intermediaries are individuals or legal entities who offer or conclude insurance contracts. This can take place through direct contact with clients or without physical presence via an electronic medium such as a website or an app. Advising clients with the aim of concluding an insurance contract is also insurance intermediation. However, if only data or information is provided, this is not deemed to be insurance intermediation.

As an insurance intermediary, you are either untied or tied. You must choose one type.

Untied intermediaries have a fiduciary relationship with their clients and look after their interests. They may not enter into any cooperation with an insurance company that restricts their freedom to act for other insurance companies simultaneously. They may not represent insurance companies.

Tied insurance intermediaries have a fiduciary relationship with an insurance company. For regulatory purposes, they are assigned to the company to which they are tied or for which they offer or conclude insurance contracts.

Detailed information about whether supervision applies and the distinction between untied and tied insurance mediation can be found in the report entitled “Amendment of the Insurance Supervision Ordinance – explanations” (German only) published by the Federal Department of Finance (FDF).

Obligations for insurance intermediaries

The obligations for insurance intermediaries from 1 January 2024 are described in the ISA and the ISO. You will find the links below. The most important points are:

• Register entry: In order to operate on an untied basis, you must register as an insurance intermediary in FINMA’s public register. To do this, you must submit application documents and information to FINMA electronically. If you are already entered in the register as untied on 1 January 2024, you can continue to operate on an untied basis. You have until 30 June 2024 to submit your follow-up documentation.
  
  You require access to the survey and application platform (EHP) to submit your follow-up documentation and for new registrations. This page explains how to proceed.
  
  In principle, tied insurance intermediaries will no longer be listed in the FINMA register.
  
  

• Financial surety: Insurance intermediaries must have professional indemnity insurance or provide an equivalent financial surety.
  
  

• Duty of information: You must provide your clients with a range of important information before concluding a contract. Untied insurance intermediaries must, in particular, disclose compensation received from insurance companies or other third parties.
  
  

• Reporting obligation: As an untied insurance intermediary, you must submit key figures and information on your activities to FINMA on an annual basis.
  
  

• Costs: Registered insurance intermediaries will incur annual supervision fees from 1 January 2024. The amount for 2024 has been set at CHF 475. The one-off registration fee is CHF 350 for individuals and CHF 750 for legal entities. There is no charge for the follow-up documentation.

Training and further education for insurance intermediaries

All insurance intermediaries must now acquire and prove that they posses the necessary skills and knowledge for their activities. The insurance industry defines these standards itself and organises mandatory training and further education. You can find more information on the website of the Insurance Industry Vocational Training Association (VBV):

• The new training for insurance intermediaries provided by the Insurance Industry Vocational Training Association

If you are already working as an insurance intermediary before or on 1 January 2024, you must fulfil the further education requirement by 1 January 2026.

Mandatory follow-up documentation for already active untied insurance intermediaries

If you have an entry in FINMA’s register as an untied insurance intermediary as at 1 January 2024, you may continue to carry out insurance intermediation on an untied basis. However, you must electronically submit the mandatory follow-up documentation to FINMA between 1 January 2024 and 30 June 2024 at the latest. In principle, this deadline cannot be extended. There are no fees for the follow-up documentation.

Changes for insurance companies

Insurance companies may only work with insurance intermediaries who fulfil the required obligations. For example, insurance companies must ensure that the untied insurance intermediaries with whom they collaborate with are listed in FINMA’s register. They must also ensure that tied insurance intermediaries comply with the relevant legal requirements. These requirements also apply to the sale of insurance products via electronic platforms.

Useful information and links

• Information on the supervision and Minimum Standards for the skills and knowledge of insurance intermediaries in accordance with the revised ISA on the website of the Insurance Industry Vocational Training Association (VBV)
  
  To the VBV website
  
  
  

• The revised ISA and ISO on the website of the State Secretariat for International Finance (SIF)
  
  To the ISA
  To the ISO
  
  
  

• Explanatory report published by the Federal Department of Finance (FDF) on the amendment of the Insurance Supervision Ordinance (supervision, solvency, tied assets, rules of conduct and insurance mediation) (German only)
  
  To the explanatory report

Contact

Questions about the registration or follow-up documentation process can be sent to FINMA at vermittler@finma.ch.

Questions about the new regulation and supervision can be sent to vermittler.regulierung@finma.ch.

The assessment of your duty to register and whether you are subject to supervision as an insurance intermediary involves the legal evaluation of a specific and isolated set of facts before a registration application is being submitted. These assessments by FINMA generally incur a fee.