ISA 2024: from registration to trust

A director checks the FINMA register before entrusting employees or customers to an insurance intermediary. The name appears, and the verification seems complete. Yet that result does not show who gives advice, in what capacity, with which expertise, for what remuneration or with what record of the recommendation. This is precisely where the revised Insurance Supervision Act, in force since 1 January 2024, shifted the question: appearing in a register does not make an entire organisation transparent. Two and a half years later, FINMA counted approximately 12,000 authorised untied intermediaries while continuing to report unauthorised activity and misconduct at the point of sale. This analysis explains the difference between tied and untied intermediaries, the duties surrounding registration and the documents that make a B2B relationship verifiable. It then identifies where a review or compliance offer may become purchasable, without turning regulation into a pretext for prospecting policyholders. General analysis updated on 6 August 2026. It does not replace legal advice or an assessment of individual circumstances by the appropriate professional.

The 2024 ISA strengthened requirements for tied and untied intermediaries: definition of their role, registration of untied intermediaries, professional capability, customer information, prevention of conflicts and supervision. It also allocated oversight between FINMA, insurance companies and intermediary organisations.

The revised Act and its implementing ordinance entered into force on 1 January 2024. The State Secretariat for International Finance places the reform within supervision based on customers’ need for protection. For a brokerage, the change therefore extends well beyond a registration number: it affects how independence is described, responsibilities are assigned and useful evidence is retained.

FINMA states that a person is an intermediary when they offer or conclude an insurance contract. Advice intended to lead to conclusion also falls within the scope, including advice through an electronic channel. A platform, salaried team or sales organisation is not excluded merely because the relationship did not begin face to face.

Supervision also became more tangible. In June 2026, FINMA said that approximately 7,000 intermediaries had newly registered since the beginning of 2024 and around 3,000 had been removed. These movements do not measure a market for engagements. They do show that status is dynamic: entry, change, control and exit must remain consistent with the activity actually carried out.

How can a status become a verifiable advice file?

How to read the diagram. The register answers a question of status. The organisation shows who assumes each obligation. The advice file then connects those responsibilities with a specific relationship. A contradiction between the three levels calls for review, not a sales promise.

Text alternative. Verification moves from status to organisation and then to the record of advice. When all three agree, the relationship can be assessed; otherwise, missing documents and responsibilities must be identified.

Sources for the diagram. FINMA pages on intermediation and intermediary duties; Fedlex, ISA and ISO as consulted on 6 August 2026.

The distinction turns on the duty of loyalty: an untied intermediary acts in the interests of its customers and may not accept cooperation that limits its independence; a tied intermediary is attached to the insurance company whose contracts it offers or concludes. That distinction determines registration and oversight.

An untied intermediary must be entered in FINMA’s public register. Employees who personally carry out intermediary activity must also be registered. A professional cannot present itself as tied and untied at the same time. This is not a branding preference: it determines the obligations and how the customer understands the advice received.

A tied intermediary is generally no longer entered in the register. Oversight is exercised through the insurance company to which the intermediary is attached. FINMA requires the company to obtain the necessary information before cooperation begins and then continuously verify compliance with statutory requirements. This also applies where distribution uses an electronic platform.

For a B2B buyer, the absence of a tied person from the register is not enough to conclude that they are acting without authority. Conversely, an untied intermediary’s presence does not guarantee every recommendation. The right first step is to identify the distribution model, responsible entity and evidence expected for that model.

The obligations that must remain verifiable after registration include capabilities, good standing, professional indemnity cover, pre-contractual information, remuneration, conflicts of interest, changes and annual reporting. They apply according to the intermediary’s status and legal form; a generic checklist cannot replace that classification.

FINMA requires capabilities and knowledge appropriate to the activity. The minimum standards for initial and continuing training, in force since 1 October 2024, provide for an admission examination and online recertification every two years. The point is not to collect certificates, but to link each person giving advice with the profile for which they are competent.

Intermediaries must also have professional indemnity insurance or equivalent financial security. Any change relevant to registration must be reported without delay through FINMA’s survey and application platform. The requirement to guarantee proper business conduct must be met continuously.

At the point of sale, information precedes conclusion. Untied intermediaries disclose, among other matters, the types of remuneration received from insurance companies or third parties. Conflicts of interest must be prevented through appropriate organisation; if a disadvantage cannot be ruled out, it must be disclosed to the policyholder before the contract. Brokerages need scripts, roles, document versions and evidence of use, not merely a legal-information page.

The FINMA register does not prove the quality of every recommendation because it confirms status and registration conditions, not whether a particular recommendation was suitable. Quality is evidenced in the file: information gathered, role disclosed, remuneration explained, conflicts addressed, limits stated and responsibility for the decision assigned.

The distinction protects both customer and professional. Presenting registration as general approval creates an expectation that cannot be met. Explaining what registration actually guarantees makes it possible to add advice-specific evidence without devaluing the register.

A useful file starts with the mandate and stated status. It then shows what information the customer received before conclusion, who made the recommendation and within what scope. It retains the versions used, the remuneration explained and how any conflict was handled. Finally, it names the person who can correct an error or respond to a complaint.

The information must remain understandable. A perfect written procedure loses its value when the adviser cannot apply it or the customer receives three conflicting explanations. Document review must therefore be connected with a sample of journeys: call, meeting, electronic signature, platform or business introducer.

The official charges to distinguish are the annual supervisory levy of CHF 475 and the one-off registration fees: CHF 350 for a natural person and CHF 750 for a legal entity. These FINMA-published amounts exclude training, organisation, insurance, documentation, tools and control time.

This separation prevents a common economic mistake. Adding the official charges gives neither the price of an engagement nor the budget for implementation. The full cost depends on headcount, sales channels, product diversity, the quality of existing procedures and the remaining work, so it is calculated with each partner before launch.

The official figures are better used as boundaries. They explain what is paid to the authority and allow the professional work to be valued separately: classifying status, assembling documents, assigning responsibilities, preparing registration or correcting an advice journey.

A review file leads to a decision when it connects a real activity with its status, then links each obligation to evidence, an owner and a deadline. Its output is not another binder, but a bounded verdict: satisfactory within the reviewed scope, correction required, specialist expertise required or journey stopped.

The first document is a simple activity map: who offers, advises and concludes, for which companies and through which channels. Next come the registration or attachment to the insurer, capability evidence, liability cover, pre-contractual information, remuneration policy and conflict management.

The brokerage then examines a small number of representative journeys. A telephone sale does not produce the same records as self-directed online onboarding. An introducer who only passes on a contact should not be described as an adviser if that is genuinely the extent of the role. Gaps become assigned actions: amend a document, clarify a role, complete a registration or seek specialist advice.

Annual reporting by untied intermediaries adds another discipline. FINMA collects indicators according to size, activity type and risk; the report for the previous financial year must be submitted by 31 May of the following year. The internal system should retrieve the data without reconstructing the entire activity at the last minute.

Which decision tree separates an admissible B2B engagement from rejected B2C prospecting?

How to read the diagram. The commercial opportunity begins with a professional facing a documented decision. Policyholder acquisition, product comparisons and promises based on regulatory fear remain outside scope.

Text alternative. An engagement is admissible when an intermediary, brokerage or insurer pays to review a real activity, records exist and a competent partner can deliver. Otherwise, the case is pre-qualified or stopped. B2C prospecting is rejected.

The most plausible buyers are new untied intermediaries, firms onboarding advisers, insurers overseeing tied networks and brokerages changing their model, remuneration or channels. The first purchase must resolve a specific event, not offer unbounded, general compliance.

A new intermediary may purchase a registration-readiness review. A company recruiting staff or acquiring a portfolio may need to connect individuals, capability profiles and roles. An insurer may need to verify a tied partner before cooperation. An established brokerage may be preparing for recertification, annual reporting or a material change.

The simplest entry product is a limited review: one scope, a document list, a few representative journeys, an interview and findings. Implementation follows only when gaps justify it. Continuity may be triggered by recruitment, a new channel, a change in remuneration, a new product range or a reporting deadline; it must not become an empty subscription.

This creates a defensible B2B acquisition proposition. It does not establish the number of immediately available accounts, the price a buyer will accept, the gross margin or the delivery capacity. Those commercial parameters must be established with a partner able to demonstrate the required expertise and evidence before acquisition begins.

Professional-client acquisition should begin with an observable event and a useful question: new registration, recruitment, reporting, recertification, a channel change or network review. Regulation establishes the context; it is neither an artificial threat nor proof that a prospect will buy.

Organic and paid search respond to explicit intentions: registration, status, training, remuneration or annual reporting. Content clarifies a distinction; email, calls and voice messages then verify the event and owner. Insurers, training bodies, lawyers, associations and software providers may act as introducers when they observe a documentable change.

Measurement follows the complete file: new account, verified event, available documents, first purchase signed and then paid. A click or meeting is not an acquisition. No volume, cost per client or revenue is published here because no enforceable partner evidence is available.

Pivots concern the segment, message, offer and capacity. If enquiries are B2C, targeting is rejected or narrowed. If professionals respond but do not buy, the deliverable and price are reviewed. If files are strong but slow to process, volume is reduced before trust is damaged.

Full acquisition cost adds media, data, tools, production, sales time and expert time, then divides the sum by attributed new clients. It is compared with actual gross margin and payment timing, never with an assumed annual value.

The Swiss insurance and broking market places this opportunity among other sector decisions. Related articles below this analysis are generated dynamically from the locale register; they are not hard-coded into the content.

Before launch, the evidence required is a recent anonymisable transaction, the price received, delivery cost, gross margin, available capacity and the partner’s professional authority. The pool of new accounts, target event and cases the offer must refuse also need to be confirmed.

The approximately 12,000 authorised untied intermediaries and movements in the register establish tension, not a volume of prospects ready to buy. The partner must document a first deliverable sold, its authority, capacity, timing and refusals: B2C, product recommendation, a promise of authorisation or a file without records.

Without that evidence, this remains market analysis. It is neither a case study nor an announcement that a campaign has been run in this vertical.

The sources defining this analysis are the ISA and ISO published on Fedlex, FINMA pages and communications on intermediaries, reporting and distribution, and the State Secretariat for International Finance’s presentation of the reform. They establish the rules cited, not commercial demand.

Materials used: Fedlex, Insurance Supervision Act and Insurance Supervision Ordinance, as consulted on 6 August 2026; FINMA, Insurance intermediaries, Obligations of insurance intermediaries, Reporting to FINMA and its 17 June 2026 communication on the first effects of supervision; FINMA’s 17 July 2024 communication on insurance companies’ distribution obligations; and the State Secretariat for International Finance briefing on the Insurance Supervision Act.

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