Insurance intermediaries

Insurance intermediaries are subject to stricter conduct and organisational requirements. The rules apply to both tied and untied intermediation, with additional registration duties for untied intermediaries.

Insurance intermediation covers the activity of offering or arranging insurance contracts for clients. The regulatory framework distinguishes between tied intermediaries, who act for one or more insurers in a defined relationship, and untied intermediaries, who act independently and must meet registration requirements before operating.

Professional standards

Intermediaries must have the knowledge and ability required for the products they distribute. They must provide clients with clear information about their role, the insurers they represent, remuneration arrangements and potential conflicts of interest. Their conduct should allow clients to understand whether advice is independent or connected to a specific insurer.

Registration of untied intermediaries

Untied intermediaries must be entered in the register before carrying out their activity. Registration requires appropriate professional qualifications, adequate professional indemnity insurance or equivalent financial security, and confirmation that the applicant satisfies the statutory requirements.

Tied intermediaries

Tied intermediaries are not registered in the same way, but they remain subject to legal duties. Insurers using tied intermediaries must ensure that distribution arrangements are properly organised and that persons acting on their behalf meet the applicable requirements.

Notifications and reports

Clients and market participants can report suspected breaches of financial market law to the authority. SFMA uses such information to identify risks, assess conduct and decide whether supervisory steps are necessary.

New regulation from 1 January 2024

The revised Insurance Supervision Act and the revised Insurance Supervision Ordinance entered into force on 1 January 2024. Since that date, the intermediation regime has applied more detailed requirements to both tied and untied intermediaries. The reform affects registrations, change notifications, training, ongoing duties and the way insurance undertakings organise their distribution channels.

The updated rules are intended to make the role of intermediaries clearer for clients. A client should be able to understand whether the intermediary acts independently or on behalf of one or more insurers, which products are being brokered, and where responsibility lies if information is incomplete or misleading.

Registration and change notifications

Untied intermediaries must be entered in the register before acting in that capacity. Applications and follow-up documentation are submitted through the electronic survey and application platform, commonly referred to as the EHP. Natural persons, legal entities, sole traders and partnerships each have documentation requirements tailored to their structure.

The registration process checks professional qualifications, reputation, financial security such as professional indemnity cover, and whether the intermediary has the organisation needed to meet its duties. Registered intermediaries must keep their entry current. Changes in activity, legal form, responsible persons, addresses, insurance cover or other relevant facts should be notified promptly through the applicable channels.

Checking intermediary activity

Before applying, a provider should classify its own activity. The key distinction is whether the intermediary is tied to one or more insurers or acts in an untied capacity. Untied activity generally requires registration, while tied intermediaries are subject to conduct and information duties but are handled through the insurers for which they act.

The classification depends on the actual relationship with insurers and clients, not merely on how the business describes itself. Remuneration, exclusivity, product selection, advisory independence and contractual authority can all be relevant. Firms should document their assessment because the classification determines the registration route and the duties that apply in practice.

Obligations for intermediaries

Insurance intermediaries must provide transparent information about their identity, role, register status where relevant, complaint options and relationships with insurers. They must avoid misleading clients about independence and must handle conflicts of interest in a way that protects clients.

Intermediaries also need appropriate internal processes for advice, documentation, complaints, remuneration and data handling. Where an intermediary employs staff or uses agents, the organisation must ensure that those persons understand the products and comply with the conduct rules.

Training and further education

Professional knowledge is a central part of the revised regime. Intermediaries must have training and continuing education appropriate to their activities. Minimum standards developed for the sector are relevant to the assessment of whether a person has the necessary knowledge and ability.

Training should not be treated as a one-off admission condition. Product changes, legal reforms and new distribution models can all create a need for updated knowledge. Firms should therefore keep records of training, refreshers and role-specific competence checks.

Changes for insurance companies

Insurance companies that use tied intermediaries must organise and monitor distribution activity. They are expected to know who acts for them, what products are distributed, how clients are informed and whether intermediaries meet the required standards. Distribution controls therefore form part of the insurer own governance.

Insurance undertakings may need to report key figures and information about intermediation, and they should align their distribution oversight with the updated legal framework. Weaknesses in intermediary management can become supervisory issues for the insurer as well as for the intermediary.

Useful information and contact

The source page provides guidance documents, EHP instructions, MyFINMA subscription information, explanatory reports, training-standard references and supervisory guidance. Questions on regulation can be directed to the published intermediation contact address, while suspected breaches of financial market law can be reported through the complaints and whistleblowing office.

Information video and practical guidance

The page also refers users to an information video on the new regulation of insurance intermediation. This material is intended to make the revised rules easier to understand for intermediaries, insurance undertakings and persons considering registration. It sits alongside written guidance because the new regime affects many practical workflows: account access, EHP submissions, status checks, training evidence, reporting and customer information.

For new registrations, the documentation differs according to whether the applicant is an employed individual, a legal entity, a sole trader or a partnership. Each applicant type must provide the documents needed to prove identity, organisation, professional knowledge, insurance cover or equivalent security and the absence of circumstances that would prevent registration. Follow-up documentation may be required if the first submission is incomplete or if the authority needs clarification.

Minimum standards and sector coordination

Training and further education are tied to minimum standards developed for the insurance intermediation sector. The standards help define what intermediaries need to know before they advise clients or broker insurance contracts. They are relevant not only for new entrants, but also for existing intermediaries who must keep their knowledge current under the revised framework.

The updated rules also require coordination between intermediaries, insurers and training bodies. Insurers need controls over tied distribution, untied intermediaries need register and competence evidence, and clients need clear information about the intermediary role. The reform therefore changes both the authorisation side and the ongoing supervision side of insurance distribution.

Supervisory information

Supervisory communications from 2023 and 2024 address transition questions and implementation expectations. The page links to Guidance 04/2023, Guidance 02/2024 and updated information on insurance intermediation, together with the revised ISA, revised ISO and explanatory report. These materials should be read together because they explain the legal basis, practical implementation and supervisory interpretation of the new regime.