Small insurers regime and relief for insurers

With the entry into force of the revised Insurance Supervision Act (ISA) and Insurance Supervision Ordinance (ISO) on 1 January 2024, insurance companies in supervisory categories 4 and 5 can benefit from regulatory exemptions if certain conditions are met. The exemptions and the conditions that apply to them are set out here.

This page sets out the relief and conditions for primary insurers (PIs) in supervisory categories 4 and 5 in the small insurer regime. Information on the relief and conditions for reinsurers (RIs) in supervisory categories 4 and 5 is available via the following link:


Relief for reinsurers

Conditions for primary insurers to participate in the small insurers regime

To participate in the small insurers regime, PIs must fulfil a number of conditions set out in Article 1c ISO. These include the following quantitative criteria:

  • An average SST ratio of 250% or more over the last three years.
  • Minimum 130% coverage of tied assets, exclusively by means of the assets defined in Article 79 para. 2 ISO.
  • 150% coverage of minimum supervisory capital at all times.
  • No loss carried forward from previous years in the accounts at 31 December and no loss carried forward in the current year.

Insurers must also have good planning, forward-looking and effective management and stable financial and business ratios.

Moreover, there may not be any ongoing supervisory measures or proceedings involving the insurance company. In the case of a run-off company there must be an approved run-off plan.

The following are excluded from the small insurers regime, as they are already eligible for other exemptions: branches, general health insurers who also offer supplementary health insurance products and primary insurers with exclusively professional counterparties eligible for exemptions under Article 30a para. 1 of the revised ISA.


In the Swiss Solvency Test (SST) report, firms do not need to provide detailed information on developments in risk-bearing capital and target capital and the impact of scenarios for a up to three consecutive years, provided the company’s risk position is sufficiently transparent at all times.

The following regular surveys by FINMA are not required:

  • Corporate governance assessment
  • Internal control system (ICS) self-assessment
  • Questions on operational risk

The reporting requirements are reduced.

  • Public disclosure: the reduction in disclosure obligations will be in line with revised FINMA Circular 16/2 “Disclosure – insurers”.
  • Auditing: case-by-case reductions in the frequency or scope of audits, depending on supervisory requirements for the various audit areas.

To be submitted annually to FINMA by primary insurers

PIs must submit an annual confirmation of compliance with corporate governance principles and the principles of risk management. This must be done using the form provided in the survey and application platform (EHP) by the end of April at the latest, which you can find under Submissions.

The mandatory planning file to be included as an attachment with the Own Risk and Solvency Assessment report is available below and must be submitted by the end of February via the delivery platform.

Questions can be sent to FINMA at