Reporting obligation for insurance intermediaries

The revised Insurance Supervision Act (ISA; SR 961.01) and the revised Insurance Supervision Ordinance (ISO; SR 961.011) require untied insurance intermediaries to submit annual reporting to FINMA.

The reporting obligation begins with the entry into force of the new regulation on 1 January 2024 and is therefore applicable for the 2024 financial year.

Article 190b para. 1 of the revised ISA states that FINMA shall collect key figures and information relating to the activities of insurance intermediaries each year.

Furthermore, paragraph 2 explains that the survey of individuals in an employment relationship (in accordance with Article 183 let. c rev. ISA) shall be conducted via the sole trader, partnership or legal entity in whose name they offer or conclude insurance contracts.

Finally, paragraph 5 gives FINMA the authority to issue technical implementing provisions regarding this reporting obligation. The standard provided for this purpose is laid out in Article 91 of the FINMA Insurance Supervision Ordinance (ISO-FINMA; SR 961.011.1).

Article 91 of the ISO-FINMA states in particular that

  • insurance intermediaries must submit the reporting for the past financial year (reference date is the end of the financial year: 31 December 20xx) to FINMA by 31 May of the following year at the latest; and

  • FINMA shall define and publish the key figures and information to be collected for the following financial year by 30 September at the latest.

As stated in Article 190b para. 4 of the revised ISA, the nature and scope of the key figures and information to be reported depend on the size, nature and risks of the insurance intermediation activity. This classification is yet to be defined based on follow-up documentation received subsequently for the first half of 2024 and shall then be applied to the survey for the financial year 2025.

With regard to the 2024 financial year, FINMA is conducting a reduced survey in order to obtain initial key information to define the structure of insurance intermediary supervision. The table below lists the key figures and information that FINMA will collect from insurance intermediaries for the 2024 financial year.

These key figures and information must be submitted to FINMA via the survey and application platform (EHP) by 31 May 2025 at the latest. For this purpose, FINMA will send a survey form to the insurance intermediaries in mid-December 2024.

FINMA will collect key figures and information from tied insurance intermediaries indirectly and as part of its regular supervisory activities regarding insurance companies.

Questions relating to the reporting obligation should be sent to the following email address: