Finland's Financial Supervisory Authority has warned that insurance has been offered publicly on websites, particularly to housing companies, through ancillary service and benefit schemes in ways that raise significant legal compliance concerns. Its supervisory review found cases where insurance cover was the central or only element of the service, prompting questions about whether the arrangements were being presented incorrectly as group insurance, self-funded group insurance or other structures. The authority said only an insurance company, its agent or an insurance broker may provide insurance under the Act on Insurance Distribution, and the same party cannot act as both agent and broker. The authority stressed that the law recognises only group insurance or self-funded group insurance, not a hybrid of the two, and arrangements combining features of both are not permitted. Where a customer can decide whether to join the cover and effectively pays the insurance-related fee, the arrangement has the essential characteristics of self-funded group insurance, regardless of how it is labelled. If a service package fee in practice corresponds to the insurance risk premium and the service has no other meaningful content, the arrangement may instead be assessed as individual insurance. It also said a policyholder may not resell insurance cover, a group cannot be created primarily to provide insurance, and brokers may not use group arrangements or public websites to market the insurance of a particular insurer openly to the public. The Financial Supervisory Authority said it has already intervened in these operating models and required corrective actions. It also called on insurance companies not to renew contracts where these non-compliant characteristics have been identified.
Finanssivalvonta2026-06-16
Finland's Financial Supervisory Authority requires corrective action on website insurance offerings that misuse group insurance structures
Finland's Financial Supervisory Authority said some insurance schemes marketed publicly on websites, especially to housing companies, appear to misuse group insurance and related structures. It said hybrid forms of group and self-funded group insurance are not permitted, some arrangements may in substance be individual insurance, and public marketing through group structures cannot be used to bypass distribution rules. The authority has required corrective actions and urged insurers not to renew non-compliant contracts.