Health insurance in 2024: when the channel became part of the evidence

For years, a health-insurance campaign could be judged by call volumes, appointments and contracts. Since 1 September 2024, that view has been inadequate. The ban on unsolicited cold calls, caps on intermediary remuneration and the requirement to prepare and sign a consultation record have shifted the centre of gravity: channel, consent, recommendation and remuneration must tell one consistent story. The change does not permit firms to sidestep the ban with an email, form or introducer. It does, however, create a concrete B2B market: audit an insurer’s or intermediary’s acquisition journey, fix breaks in the chain and establish usable evidence. This analysis explains the rules, the published remuneration levels, the role of the consultation record and how to test a review offer without prospecting individual policyholders or exploiting their concerns. General analysis updated on 7 August 2026. It does not replace legal advice or instructions from the Federal Office of Public Health or the competent authority.

The framework in force from 1 September 2024 bans unsolicited cold calls, limits intermediary remuneration and requires a consultation record to be prepared and signed. It makes rules previously contained in a voluntary industry agreement binding on all insurers, with the aim of harmonising practice across the market.

The Federal Council adopted the ordinance on 14 August 2024. The act and its implementing ordinance entered into force a few weeks later. The change covers social health insurance and supplementary insurance, with different remuneration arrangements. The FOPH supervises the framework and receives complaints, including those concerning cold calling.

For a commercial team, the reform involves more than removing a call list. It requires the origin of every contact, the status of the relationship, the adviser, the relevant product and the signed record to be mapped. Lawfully holding contact details does not prove that the channel, mandate and consultation collectively comply with the rules.

How to read the diagram. The evidence begins before the consultation and continues after signature. If the origin of the contact is not permitted, the rest of the journey must not be activated.

Text alternative. The origin is checked and an impermissible contact is stopped. A permitted contact may lead to documented advice, a signed record, controlled remuneration and archiving under the applicable rules.

A call is considered cold when the person has no business relationship with the insurer, has not been a customer for more than thirty-six months or was not recommended by someone they know. Classification therefore depends on demonstrable facts, not a generic ‘consent’ box completed after the call.

This definition requires sound data management. The end date of a relationship, the identity of the person making a referral and the scope of a callback request must be retained in an intelligible form. An old, purchased or enriched list does not create a relationship. A contact generated by a comparison platform must be assessed against the actual journey and contractual responsibilities.

The explanatory report makes clear that switching channel must not defeat the purpose of the rules. A strategy should not therefore replace a call automatically with an electronic message. It must redesign how the relationship begins: requested content, an identifiable referral, a voluntary event, a documented partnership or an explicit request for advice.

The FOPH’s 2024 activity report gives a cap of CHF 70 for each social health-insurance contract concluded and sixteen monthly premiums for each supplementary insurance product taken out. These limits concern intermediation remuneration; they establish neither actual margin nor total acquisition cost nor the quality of the advice.

The compulsory-health-insurance cap immediately exposes the fragility of expensive acquisition. Media, data, tools, supervision, call time, advice and control must fit an economic model compatible with permitted remuneration. Counting only the cost of the initial contact conceals the more substantial work: verifying origin, conducting the consultation and retaining the evidence.

For supplementary insurance, the reference to sixteen monthly premiums does not produce one universal amount because the premium depends on the product. Teams must model each range separately and distinguish gross revenue, any clawbacks, compliance costs and margin. A campaign that remains profitable only by bypassing controls is both economically and legally unacceptable.

A signed consultation record changes the journey because it turns the conversation into a verifiable sequence. It should connect the adviser’s identity, stated needs, information supplied, products discussed and customer confirmation. Its quality depends on the actual consultation: a signature cannot cure incomplete advice or a pre-filled document.

The form should support the conversation, not replace it. If the fields are too burdensome, advisers work around the tool; if they are too vague, the evidence becomes cosmetic. Design therefore starts by observing a sample of consultations, identifying the decisions and removing data for which no useful purpose can be shown.

The signature must be attributable and archived with the correct version. The process also needs to handle refusal to sign, correction of an error, remote consultations and delivery of a copy. These are useful tests of maturity: a journey is not robust if it works only in the ideal case.

The first B2B purchase may focus on this chain alone. The partner examines one channel, one product and a sample of consultations, then delivers a list of breaks, owners and priority corrections. It does not certify the entire organisation or replace the authority.

Each channel must be audited for origin, consent, handover, advice and evidence. Search, referrals, events, comparison platforms, forms and calls do not create the same risks. Consistency must be checked where one system hands over to another and information can be lost, reinterpreted or attributed to the wrong party.

Audits often expose breaks between communications and sales. A form collects a general enquiry, which the call centre then treats as an invitation to sell. A partner is paid without its role being clear. The consultation record is signed, but the origin of the contact can no longer be retrieved. The correction must address the handover, not merely the visible wording.

Plausible buyers include health and supplementary insurers, appointed intermediaries, contact centres and platforms that organise initial contact. The first purchase is a bounded review of one journey or channel. The market does not include policyholders to be won or consumer lists to be exploited.

A new intermediary, change of supplier, customer-relationship-management migration or product launch creates an observable event. Management then needs to confirm that the rules have been translated into the new journey. This timing supports useful B2B outreach only after the partner has demonstrated that it can start, deliver and invoice within the agreed period.

National contract volumes do not become a prospect list. Acquisition is organised around named accounts and declared changes. An entry offer might examine twenty journeys, one product and one period, then report the gaps. Full implementation follows only once a genuine problem has been demonstrated.

The insurance and broking market page connects this opportunity with the ISA’s general duties without conflating health-insurance intermediation with other distribution models.

Compliant acquisition first attracts a voluntary enquiry or relies on a demonstrable relationship. Content, search, events, introducers and documented partnerships may precede a requested callback. The telephone remains a processing channel when authorised; it cannot create consent retrospectively. Every channel must preserve the origin and scope of the contact.

How to read the diagram. Outbound contact follows a voluntary signal or qualified relationship. The consultation record and the economics are measured at the end of the same journey.

Text alternative. A recorded enquiry is qualified and a callback occurs only when permitted. The consultation then produces a signed record and a complete economic measure.

Search reaches people already looking. Content helps them compare without triggering an immediate call. Events provide an explicit choice of follow-up. Introducer networks are controlled through contracts and sampling. Advertising data are never treated as a request for advice without further evidence.

The campaign must pivot if total cost exceeds the permitted economics, contacts cannot be attributed, the consultation record impairs the advice or control capacity is saturated. It must stop when the model depends on cold contact, reconstructed consent or remuneration incompatible with the framework.

Management should follow a small set of readable indicators: the share of contacts with a complete origin, the rate of genuinely requested callbacks, records signed without correction, processing time, retained contracts and total cost per contract. High volume with doubtful origins is not performance. A smaller channel may be preferable if it creates a clearer relationship and sustainable margin.

A pivot may change the segment, content, form, partner or product. It must never move the same prohibited practice to another medium. Compliance retains a right of veto; the commercial team records decisions and reduces pressure as soon as controls deteriorate.

Recurrence comes from real changes: a new channel, partner or remuneration model, a system migration, team training or a periodic sample review. Every engagement has an objective and a defined exit. Ongoing work is not vague monitoring; it checks an evidence chain whose risks and frequency have been agreed.

After the initial audit, the partner may support corrections, train teams and then review a sample at a defined interval. Continuity is measured through work actually commissioned and paid for. Hypothetical revenue, contracts attributed to the wrong channel and automatic renewals are excluded.

Before launch, the partner documents its expertise, insurance, secure access, proposed price, available monthly capacity, expected margin and escalation procedure. getfishnet then evaluates acquisition through paid diagnostics, cost per new account and the value of justified follow-on work, without publishing the client’s confidential data.

The complimentary eligibility check compares your acquisition challenges with the framework, your channels, evidential capacity and the economics of the first purchase. It determines whether our services match your points of friction and whether there is a basis for a tailored strategy, without commitment or a promise of results.

The authoritative sources used are the Federal Council, the Federal Office of Public Health, the act and ordinance governing intermediary activity and the supervision authority’s 2024 activity report. They establish the rules and caps; they demonstrate no mandate volume or campaign result.