LCD 2025: what's changing for insurance brokers

The revised Insurance Supervision Act (ISA/LSA) — often loosely called LCD 2025 — comes fully into force on January 1, 2026. This reform profoundly transforms the practice of the broker profession in Switzerland. Here is the essential information for insurance brokers and advisors.

1. FINMA register mandatory for non-tied brokers

All non-tied insurance intermediaries (= independent brokers working for several insurers) must appear in the FINMA public register. Without this registration, you can no longer collect commissions.

Registration requirements

• Initial training completed (IAF, IFFP, AFA diploma or equivalent)
• Clean criminal record (extract < 3 months)
• Professional liability insurance minimum coverage 2M CHF per claim
• Organizational compliance documented (internal procedures)
• Payment of a deposit of 10,000 CHF (or bank guarantee)

Average processing time by FINMA: 6 to 14 weeks depending on the complexity of the file.

2. Continuing education: 15 hours per year minimum

Each broker must demonstrate 15 hours of continuing education per year, of which at least 5 hours on compliance (AMLA, FADP, duty to inform, conflict-of-interest management).

Organizations such as AFA (Federal Association of Insurers), ASSPP (Swiss Association of Pension Professionals), or Cicero offer recognized programs, often remote. Annual budget: 600 to 1,500 CHF per advisor.

3. Enhanced duty to inform

Before concluding any contract, the client must receive a written document stating clearly:

• The status of the broker (tied or non-tied)
• The compensation received (commission, fees, amount or range)
• The insurer partners usual
• The potential conflicts of interest and how they're handled
• The remedies in case of dispute

This document must be signed by the client BEFORE any concrete proposal. The signature can be handwritten, electronic (Skribble, Yousign), or by clear acknowledgment of receipt.

4. Regulated brokerage commission cap

Forsupplementary health insurance, the commission per contract is now capped at:

For life insurance and tied pension (3a), the existing caps remain in force (FINMA ARC 2008).

5. Documentation of advice (report)

Each appointment must generate a report signed by the client, specifying:

• The identified need (situation analysis)
• comparative analysis (at least 2-3 products reviewed)
• The recommended product and its justification
• The fees and commissions involved
• The discarded alternatives and the reasons

Mandatory retention: 10 years. In case of a client dispute (proceedings before the ombudsman), the absence of documentation = presumption of fault by the broker.

What about penalties?

FINMA can impose: a warning, a fine up to 100,000 CHF, a temporary ban on practicing (6-24 months), permanent license withdrawal. FINMA has already sanctioned 14 brokers in 2025 — the trend is accelerating in 2026.

What to do concretely before the end of 2026?

1. Check your registration in the FINMA register (or file the application immediately if not done)
2. Update your professional liability insurance (minimum coverage 2M CHF)
3. Sign up with a continuing education organization recognized
4. Redo your client information documents (with compensation disclosure)
5. Set up a 10-year archiving system (secure Swiss cloud like Infomaniak or Tresorit)
6. Audit your sales stack (CRM, contracts) for compliance
7. Train your teams on the new obligations

And what about leads?

The enhanced duty to inform requires increased traceability of the client journey. The leads you buy must come with timestamped opt-in proof, an identifiable source, and an active opt-out option. This is non-negotiable.

At LeadPartner, each lead is delivered with its opt-in certificate (URL, IP, timestamp, campaign source) — automatically compliant with GDPR/FADP and ISA requirements. If that's not the case with your provider, it's a red flag.