Intermediary commission

What is the intermediary commission?

The intermediary commission is the remuneration a health insurer pays a person or company that brings it a new customer. Intermediaries can be employees of an insurer, independent agencies, brokers or online comparison portals. The law does not call the remuneration a commission; it covers all benefits with a monetary value: commissions, courtages, fees, discounts, bonuses and the costs of purchased addresses and appointments.

In health insurance, there are two types of intermediation with different rules. In basic health insurance, an intermediary is anyone who, in the interest of one or more insurers and in return for remuneration, proposes or enables a person to join a health insurer. In supplementary insurance, an intermediary is anyone who offers or concludes insurance contracts in the interest of an insurer or other persons. This expressly includes websites with an economic interest that propose insurance according to individual criteria or compare it in a ranking.

The distinction between tied and untied intermediaries is important. Untied intermediaries have a fiduciary relationship with you and act in your interest. They must be entered in the register of FINMA. All others are considered tied, because they work on behalf of one or more insurers.

How it works

Since 01.09.2024, binding rules from the insurers’ industry agreement have applied to all health insurers. The Federal Council has declared the most important points generally binding so that they also apply to health insurers that have not signed the agreement.

Rule	Basic health insurance (KVG)	Supplementary insurance (ICA)
Cap	CHF 70 variable remuneration per insured person	16 net monthly premiums (invoiced) per contract
Repayment if terminated by day 365	100 %	100 %
Repayment if terminated on days 366–730	at least 50 %	at least 50 %
Advice record	required for every remuneration	required for every remuneration
Cold calling by telephone	prohibited	prohibited

The costs of purchased leads, i.e. contact addresses and appointments, also count as remuneration. An insurer therefore cannot get around the cap by paying a portal a price per address instead of a commission. The only exception is leads that an insurer generates itself for its own sales.

The advice record must contain at least the date, the names of the customer and the adviser, confirmation that the appointment did not result from cold calling by telephone, and the consent of both sides, by signature or digitally. Cold calling means calling people with no business relationship, former customers after more than 36 months, or people who have opted out.

An additional duty of disclosure applies to untied intermediaries. They may only accept remuneration if they have first expressly informed you of its type and amount. If you pay the intermediary yourself, for example with a fee, they must pass the commission on to you, or you must expressly waive it.

Legal basis

The legal bases for the caps are in two acts. Art. 19b of the Health Insurance Supervision Act (KVAG) allows insurers in basic health insurance to conclude an agreement on telephone marketing, training, limiting remuneration and advice records; at the request of insurers covering at least 66 % of insured persons, the Federal Council can declare parts of it generally binding. Art. 31a of the Insurance Supervision Act (ISA) contains the same rule for supplementary insurance. Art. 19a KVAG and Art. 40 ISA define who is an intermediary.

The Federal Council implemented the rules with the ordinance of 14.08.2024, in force since 01.09.2024. For basic health insurance, Art. 35b of the Health Insurance Supervision Ordinance (KVAV) with Annex 2 applies (item 9.1.1: CHF 70); for supplementary insurance, Art. 190e of the Insurance Supervision Ordinance (ISO) with Annex 7 (item 9.1.2: 16 net monthly premiums). Repayment is set out in item 9.2 in each case, the advice record in item 8.2.

Disclosure by untied intermediaries is governed by Art. 45b ISA, the general duty of all intermediaries to provide information by Art. 45 ISA. Breaches of the generally binding rules in basic health insurance are punishable under Art. 54 para. 3 let. h KVAG with a fine of up to CHF 100,000, or up to CHF 20,000 if committed through negligence.

Example: what a switch may earn the intermediary

Sandra, 41, switches basic health insurance through an intermediary and takes out supplementary hospital insurance with the new health insurer. The supplementary insurance costs her CHF 60 net per month; the amount has been chosen for illustration. The caps are the statutory ones.

Contract	Basis	Maximum
Basic health insurance	CHF 70 per insured person	CHF 70
Supplementary hospital insurance	16 × CHF 60 net monthly premium	CHF 960
Total		CHF 1,030

What this means for you

A commission is legal and common. What matters is that you know who earns from it and that the recommendation matches your needs. Ask every adviser these questions:

1. Are you tied or untied? They must give you the answer. You can find untied intermediaries in FINMA’s register.
2. How much is your remuneration for this contract? Untied intermediaries must disclose this; with tied ones, you may ask anyway.
3. Do I really need the supplementary insurance? The higher remuneration lies in supplementary insurance. So check the benefits and premium yourself.

You do not need an intermediary for basic health insurance: the benefits are the same at all health insurers, and you compare premiums in the premium calculator. The steps for switching are under Switching, and the insurers’ key figures under Health insurers. If someone calls you unsolicited to sell you health insurance, this generally breaches the ban on cold calling.

This platform also earns money from intermediation. It is operated by FinanceRock GmbH, registered as an untied intermediary in the FINMA register under number F01496799. How we are remunerated is set out under Disclosure and in the intermediary information. The ranking in the comparison never depends on remuneration.

Common mistakes

• Thinking advice is free. You do not pay for it directly, but the insurer remunerates the intermediary, and these costs feed into the premiums.
• Signing the advice record without reading it. Among other things, it confirms that the appointment did not result from an unwanted call. Only sign what is true.
• Not asking about remuneration. Untied intermediaries must disclose it. If the information is missing, ask.
• Taking out basic and supplementary insurance together without comparing. The two contracts are independent. You can have them with different insurers.

We explain how we handle data, sources and remuneration under How we calculate.