12 December 2025

New registration requirement for tied insurance intermediaries

  • Articles
  • Legal
  • Banking / Insurance
  • Regulatory Compliance

The VBV industry register will apply from January 1, 2026: tied agents will need to register and provide proof of knowledge; independent agents will remain with FINMA.

  • Dr. Kiril R. R. Haslebacher

    Legal Associate

From 1 January 2026, the new VBV industry register will come into force in Switzerland. Tied insurance intermediaries must be registered in this register in order to be allowed to advise customers on insurance matters and conclude insurance contracts with them. Tied insurance intermediaries must now provide uniform, formal proof of knowledge (VBV examination/qualification profile). Registration is not mandate-related via the insurance company, but primarily knowledge- and qualification-related. Untied insurance intermediaries must continue to register directly in the FINMA public register as before.

Insurance intermediaries

Regardless of their designation, insurance intermediaries are persons who offer or conclude insurance contracts. This can be done either in direct contact with customers or via an electronic platform. Advising customers with a view to concluding an insurance contract is also considered insurance intermediary activity.

A distinction must be made between untied and tied insurance intermediaries: Untied insurance intermediaries have a fiduciary relationship with policyholders and act in their interests, while all others are considered tied insurance intermediaries. All insurance intermediaries must decide whether they want to operate as tied or untied insurance intermediaries. It is not permitted to operate as both a tied and an untied insurance intermediary at the same time.

Since the revised Insurance Supervision Act and the revised Supervision Ordinance came into force on 1 January 2024, increased requirements apply to all insurance intermediaries. This also applies to compulsory training and continuing professional development.

Training and continuing education requirements

Under the Insurance Supervision Act, insurance intermediaries must have the skills and knowledge necessary for their work. FINMA has recognised the self-regulation developed by the Berufsverband der Versicherungswirtschaft (VBV) as binding minimum standards. These training and continuing education requirements therefore apply to all insurance intermediaries, both tied and untied.

The skills and knowledge required for insurance intermediation are defined in four qualification profiles, each with its own performance requirements, namely

  • "All sectors" profile
  • "Life" profile
  • "Non-life" profile
  • "Supplementary health insurance" profile

To be licensed as an insurance intermediary, proof of the relevant skills and knowledge must be provided by means of an examination. The examination can be taken flexibly and independently of location. Digital certificates are issued upon passing the examination. While untied insurance intermediaries can use these certificates to demonstrate the skills and knowledge required for registration in FINMA's public register of insurance intermediaries, tied insurance intermediaries are automatically entered in the VBV's new industry register upon successfully passing the examination.

To ensure that active insurance intermediaries keep their specialist knowledge up to date, recertification every two years will also be introduced from 2026. All insurance intermediaries will be invited by the VBV to take this online check every two years.

Automatic transfer from the Cicero register

Until the introduction of the new VBV industry register on 1 January 2026, the Cicero register was used to document and monitor the qualifications and further training of insurance intermediaries. The Cicero register will be discontinued at the end of 2025 and replaced by the new VBV industry register. Tied insurance intermediaries who are registered in the Cicero register by 31 December 2025 will be automatically entered into the new VBV industry register without having to take another admission test. Tied insurance intermediaries who are not registered in the Cicero Register on the cut-off date of 31 December 2025 will only be entered in the VBV industry register from 1 January 2026 after passing an admission test.

Do you have any questions about the new registration requirement for untied insurance intermediaries, or do you need assistance in fulfilling your obligations as an insurance intermediary? Our experts from the Banking/Insurance department will be happy to support and advise you.-

 

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