Intermediaries, brokers, comparison sites: who receives how much commission

Who earns money from a change of health insurer

If you switch health insurer through an adviser, a broker or a comparison site, the new insurer often pays remuneration for it. This is legal and common in Switzerland. Since 01.09.2024, however, the amount of this remuneration has been capped for all health insurers, and there are duties to advise and to disclose.

The law does not speak of commission but of remuneration. This means all monetary benefits to intermediaries linked to a contract: commissions, brokerage fees, discounts, bonuses and explicitly also the costs of purchased leads, i.e. contact addresses and appointments (no. 5.4 of the industry agreement, Annex 2 of the Health Insurance Supervision Ordinance, KVAV). In everyday language, all of this is called intermediary commission.

In basic health insurance, an intermediary is anyone who, in the interest of one or more insurers and in return for remuneration, suggests or enables insured persons to join an insurer, regardless of what they are called (Art. 19a of the Health Insurance Supervision Act, KVAG). In supplementary insurance, an intermediary is anyone who offers or concludes contracts in the interest of insurers or other persons (Art. 40 para. 1 of the Insurance Supervision Act, ISA).

The caps at a glance

The basis is the health insurers’ industry agreement of 22.03.2024. The Federal Council declared its key points binding on all insurers as of 01.09.2024: for basic health insurance in Art. 35b KVAV with Annex 2, for supplementary insurance in Art. 190e of the Insurance Supervision Ordinance (AVO) with Annex 7.

Rule	Basic health insurance (KVG)	Supplementary insurance (ICA)
Cap	CHF 70 in variable remuneration per insured person	16 net monthly premiums (invoiced) per contract
Purchased addresses and appointments	count towards the remuneration	count towards the remuneration
Clawback if the contract lasts up to 365 days	100 %	100 %
Clawback if the contract lasts 366 to 730 days	at least 50 %	at least 50 %
Record of the advice meeting	required for any remuneration	required for any remuneration
Cold calling by phone	prohibited	prohibited

Two points stand out. First, the cap in basic health insurance is fixed and low, while in supplementary insurance it depends on the premium and can be many times higher. Second, a contract only pays off for the intermediary if it lasts longer than a year. From day 731, each insurer decides for itself whether to claw back remuneration (no. 9.2 of the industry agreement, Annex 2 KVAV).

Record of the advice meeting and disclosure

Record of the advice meeting. An insurer may only pay remuneration for an application submitted by an intermediary if a record of the advice meeting meeting the minimum standards is attached (no. 8.2 of the industry agreement, Annex 2 KVAV). It contains at least the date, your name and that of the adviser, confirmation that the appointment did not come from cold calling by phone, and your consent, by signature or digitally. Read it before you agree.

Duty to provide information for all intermediaries. Before you apply for a contract, every intermediary must give you their name and address, say whether they work as a tied or untied intermediary and for which insurers, who is liable for errors and how they process your personal data (Art. 45 ISA).

Disclosure for untied intermediaries. An untied intermediary has a fiduciary relationship with you and acts in your interest (Art. 40 para. 2 ISA). They must be entered in the public register of FINMA (Art. 41 ISA). They may only accept remuneration from insurers if they have first explicitly informed you of its type and amount (Art. 45b paras 1 and 3 ISA). If the amount is not known in advance, they state the basis of calculation and the range; on request, they disclose the amounts actually received. If you pay them yourself, for example with a fee, they must pass the remuneration on to you or you explicitly waive it (Art. 45b para. 2 ISA).

Appearance of independence. Anyone who gives you the impression of advising as an untied intermediary must also meet the requirements for untied intermediaries (Art. 182b AVO). So a site that calls itself neutral and earns money from contracts cannot fall back on the rules for tied intermediaries.

Sample calculation: what a switch may bring in

Example with fictitious people. Tim, 38, and Selin, 36, switch basic health insurance through a broker. At the same time, Tim takes out supplementary hospital insurance and Selin dental insurance. The net monthly premiums for the supplementary insurance are assumed; the caps are the legal ones.

Contract	Rule	at most
Basic health insurance Tim	CHF 70 per insured person	CHF 70
Basic health insurance Selin	CHF 70 per insured person	CHF 70
Supplementary hospital insurance Tim, assumed CHF 60 a month	16 × CHF 60	CHF 960
Dental insurance Selin, assumed CHF 25 a month	16 × CHF 25	CHF 400
Total	including purchased addresses and appointments	CHF 1,500

The calculation does not mean that supplementary insurance is bad. It shows where the intermediary’s interest is greatest. Whether supplementary insurance suits your needs is something you decide based on its benefits and premium, not on a recommendation over the phone. The page Supplementary insurance gives an overview.

Comparison sites: what you should know

Many comparison sites are financed by remuneration from insurers, directly or through a sister company acting as a broker. They count as intermediaries if they have an economic interest and suggest insurance policies based on your details or show them in a ranking with a price and product comparison (Art. 182a para. 2 AVO). According to the association prio.swiss, the industry agreement applies regardless of whether intermediaries are self-employed or employed by an online comparison site or an insurer.

For you, this means: for every site, check who is behind it, whether it earns money from contracts, whether it shows all insurers and whether you can see results without giving a phone number. For basic health insurance, you do not need a site with an interest in brokering: the benefits are the same with all insurers, and the premiums are public. You can compare them in the federal premium calculator at priminfo.admin.ch or in our premium calculator, which is based on the same FOPH data and shows all offers without asking for contact details.

What happens in the event of breaches

Formally, the rules bind the insurers: they may only pay remuneration to intermediaries who comply with them. If an insurer disregards a rule that has been declared binding, the supervisory authority can prohibit it from paying external intermediaries for up to one year or limit its costs for acquiring customers (Art. 38a KVAG). In basic health insurance, breaches of the binding rules are punished with a fine of up to CHF 100,000, or up to CHF 20,000 if committed through negligence (Art. 54 para. 3 let. h and para. 4 KVAG).

The FOPH explains where to report breaches: breaches by intermediaries and in supplementary insurance to FINMA, breaches by insurers in basic health insurance to the FOPH, unwanted advertising calls to SECO and violations of the industry agreement to the reporting office fair-mittler.ch. How this works for calls is explained in the article Advertising calls about health insurance.

The signatory associations can terminate the industry agreement itself with twelve months’ notice to the end of a calendar year, for the first time as of 31.12.2026 (no. 11.1). The legal basis for declaring it generally binding is Art. 19b KVAG.

Five questions for every adviser

1. Are you tied or untied, and which insurers do you work for? Every intermediary must give you this information.
2. How much remuneration do you receive for this contract? Untied intermediaries must disclose it; you may still ask tied ones.
3. Where did you get my address and phone number? If the contact came from an unwanted call, the record of the advice meeting must not confirm the opposite.
4. Which insurers did you compare? A comparison of a few insurers is not a market comparison.
5. Do I need the supplementary insurance you are suggesting? This is where the higher remuneration lies. Read the conditions yourself and use the 14-day right of revocation (Art. 2a of the Insurance Contract Act, ICA) if you change your mind.

How this platform earns money

This platform is also an intermediary. It is operated by FinanceRock GmbH, registered as an untied intermediary in the FINMA register under number F01496799. The order in the comparison never depends on remuneration, you see results without giving contact details, and advice is only given if you request it yourself. How we are paid is set out under Disclosure, how we calculate under How we calculate.

Common mistakes

• Thinking advice is free. You do not pay directly, but the remuneration is part of the insurer’s costs and feeds into the premiums.
• Confirming the record of the advice meeting without reading it. With your consent, you also confirm where the appointment came from.
• Taking out basic and supplementary insurance in the same conversation. The contracts are independent. You can switch basic health insurance without advice, and check supplementary insurance in your own time.
• Cancelling existing supplementary insurance before the new one is in place. The new insurer may ask health questions and turn you down. Why this is the biggest disadvantage of switching is explained in the article Disadvantages of switching health insurer.

You can switch basic health insurance without an intermediary: compare premiums, register with the new insurer, cancel by 30 November. All steps are under Switching health insurer, the insurers with their key figures under Health insurers, and all articles on the subject in the topic Switching health insurer.