ICA 2022: the contract is no longer decided at signature alone

An insurance product may be legally sound yet fail in practice. Information arrives too late, the right of revocation is hard to find, a notice of termination falls between two systems or a claims handler works from a different version of the terms. When the revised Insurance Contract Act entered into force on 1 January 2022, it made these breaks more costly to ignore: new rights, stronger information duties, a five-year limitation period for the claims concerned and wider termination options. This is not an article-by-article summary. It follows the contract as a customer experiences it, from proposal to claim, to identify where evidence should exist and who must act. It shows how an insurer, broker or specialist provider could commission a short review, correct one priority journey and establish recurring oversight without promising that disputes will never occur. General analysis updated on 7 August 2026. It does not replace individual legal advice or the interpretation of the competent authorities or courts.

The revised ICA strengthened the position of policyholders and modernised several stages of the contract: a fourteen-day right of revocation, information rules, provisional cover, wider termination options and a limitation period extended from two to five years for the insurance claims concerned. Wording, interfaces, correspondence, teams and systems all had to align.

The Federal Council set 1 January 2022 as the commencement date. The Act governs the contractual relationship between insurance companies and their customers. Amending general terms and conditions was therefore insufficient: each touchpoint needed to provide the correct information, receive and date the customer’s decision, and make it available to the team responsible for carrying out the contract.

The right of revocation illustrates the point. Customers generally have fourteen days to withdraw within the scope of the rule. If the digital journey, the document supplied and customer service describe different rules, the risk lies not only in the wording but in operational inconsistency.

The useful first purchase is a review of one priority journey, such as digital onboarding for a product or termination. It compares the rule with supplied materials, screens, messages, records and internal procedures. The output is an assigned register of gaps, never a blanket assurance of compliance.

Changing the general terms and conditions was not enough because several channels and systems execute the contract. A correct clause may be contradicted by an old form, sales script, automated response or claims procedure. Operational compliance requires a shared version, an effective date, named owners and controls at each touchpoint.

A journey may involve product, legal, distribution, customer service, IT and claims teams. Each holds only part of the picture. A review should therefore begin with a concrete case: which document does the customer see, what action can they take, which system records it and which team receives the alert?

This method exposes silent breaks. A termination notice may arrive on time but be indexed too late; provisional cover may be mentioned without a visible start date; an obsolete brochure may remain in circulation through a distributor. The handover between teams needs as much attention as the wording itself.

How to read the diagram. A rule is useful only when the right can be exercised, recorded and processed. Missing evidence triggers a correction assigned to an owner.

The first journey to review combined volume, legal change and the cost of error: digital onboarding, revocation, termination, a premium change or the handling of a frequent claim. Priority depended not on the most abstract issue, but on the number of contracts affected, the channels involved and the ability to correct the journey quickly.

Selection starts with active products and the most frequent customer events. It adds complaints, known errors, document versions and transformation projects. An old, low-volume product may remain secondary; a new journey distributed by several partners may take priority even before any dispute arises.

The initial diagnostic can be commissioned without waiting for a long budget cycle: one product, one channel, a few test cases and a findings session. Before the service is offered, the partner must state its proposed price, delivery window, relevant expertise and available correction capacity. The service should not be sold without access to the relevant versions and owners.

Testing revocation means reproducing the complete journey: information before conclusion, the start date, notification method, proof of receipt, the effect in the system and any reimbursement. The clause is only one link. The test must show that a customer can exercise the right and the company can process the request without a break.

The scenario uses a fictitious contract and controlled dates. It checks what customers see, how they communicate their decision and what follows in the systems. It also examines exceptions applicable to the product; a general rule must not be extended mechanically to every contract.

This level of detail makes the reform easier for teams to apply. Instead of memorising the entire change, each team sees the action it must perform and the evidence it must retain. The same scenario can then verify the correction.

The five-year limitation period for the claims concerned extends the time during which a file may need to be understood and defended. Retention, version legibility and access to decisions must be reviewed. Keeping more material is not enough: the company must connect each record with the contract, customer and event.

An isolated archived document does not explain a decision. The applicable version, date supplied, acceptance, changes and relevant exchanges all need to be retained. Retention must also comply with other applicable rules; the ICA does not justify indiscriminate accumulation of personal data.

The review identifies source systems, deletion rules, transfers between tools and formats that may become unreadable. It assigns retention decisions to the appropriate owner and flags conflicts with data-protection policy. A specialist engagement can then address document architecture without conflating legal and technical advice.

The B2B pool includes insurers, brokers, distributors and service providers launching a product, redesigning onboarding, changing terms or integrating a portfolio. Those events make a review purchasable. Outreach does not target individual policyholders or claim from a public signal that a company is in breach.

A launch, IT migration, distribution partnership, acquisition or internally reported rise in complaints may create a need. The commercial message should present a hypothesis: does your transformation affect information, revocation or termination, and would you like to test one journey before rolling it out?

The insurance and broking market page connects this decision with other changes to supervision and intermediation. Content answers search intent, professional networks provide trust and direct contact is limited to relevant events. One client’s results are never used to manufacture a universal promise.

Corrections should proceed by journey and risk, with a reference version and an owner responsible for release. Defects that prevent a right from being exercised take priority over presentational improvements. A correction closes only after testing in the live channel, informing relevant distributors and withdrawing obsolete versions.

Implementation uses one register: defect, affected products, owner, version, date, test and decision. One journey can be corrected while another remains under analysis, provided the exposure is known and handled by the competent owner.

A review becomes recurring when there is a new product, release, channel, distribution partner or change of rule. A periodic control may also sample completed journeys. Continuity is legitimate only when each cycle has a trigger, deliverable and closure decision.

The partner may maintain an evidence library, test major releases and examine a sample of files. The work is not an endless rereading of the same clauses; it verifies that the journey remains aligned after each change. Recurring revenue exists only when a new intervention is invoiced and paid.

Commercial measurement follows paid diagnostics, conversion time, margin, commissioned corrections and cycles renewed for a documented reason. Clicks and meetings remain intermediate indicators. No hypothetical performance is presented as a campaign result.

The campaign must state that the diagnostic is limited in scope, does not guarantee general compliance or the absence of disputes, and leaves legal decisions with their proper owners. The partner must confirm insurance, expertise, confidentiality, price and capacity. Without these, the opportunity remains at partner-research stage.

The authoritative sources used are the State Secretariat for International Finance, the Federal Council, the Insurance Contract Act and official explanatory material. They establish rights and dates. They publish no advisory price, conversion rate or promised economic outcome.

The complimentary eligibility check examines your offer, acquisition challenges, purchasable journeys and correction capacity. It validates no contract. Its purpose is to establish whether getfishnet and your team can assemble the evidence, account pool and delivery model required for a tailored strategy.