Structured Products Under Scrutiny: SFSA’s 2023 Review of Insurance Intermediaries

In 2023, the Swedish Financial Supervisory Authority ("SFSA") embarked on an extensive examination of insurance intermediaries[1]. This review encompasses a comprehensive evaluation of the financial instruments they mediate and the potential impact of commissions and compensation on their advisory services. Building upon a 2021 survey that scrutinized new rules governing commissions and independent advice[2], SFSA's latest audit seeks to address persistent concerns.

The 2021 Survey Findings

In its 2021 survey, the SFSA brought to the forefront long-standing concerns surrounding structured products and the substantial commissions associated with them. The survey not only uncovered a noticeable reduction in commission rates over the years, dropping from as high as 26 percent in 2016 to a more modest range of 3 to 6 percent in 2021, but it also emphasized a growing trend towards increased fees directly charged to customers. While this shift in compensation models has improved transparency, it has not entirely mitigated the potential risks associated with advisory services and high-profit product categories.

SFSA’s report from 2021 underscored the positive momentum in commission handling but noted that substantial commissions were still being charged by securities firms and insurance distributors, often in connection with advisory services and other distribution methods. This observation laid the groundwork for continued SFSA vigilance.

The 2023 Review of Insurance Intermediaries

SFSA’s 2023 review focuses squarely on financial instruments offered within insurance policies, particularly those marketed directly to consumers[3]. It delves into the adequacy of consumer protection mechanisms in place. The review aims to determine the extent to which intermediaries are marketing complex and high-risk financial products to consumers. Additionally, it evaluates how packaged products within insurance solutions influence advisory practices and compliance with legal obligations.

Derivatives and structured products, known for their complexity and associated risks, fall under SFSA’s scrutiny. These products often pose challenges for consumers to comprehend, while their high premiums and substantial risks make them a cause for concern.

The review also casts a critical eye on the compensation models used by brokers. SFSA aims to uncover whether intermediaries receive targeted commissions for particular product types, potentially creating conflicts of interest. This, in turn, may lead to advice that prioritizes products with high commissions over consumer needs.

Johannes Petersson, senior financial inspector at SFSA’s Conduct Supervision Department, highlights the elevated risks posed by certain product categories to consumers. As such, SFSA will likely subject intermediaries providing advice on riskier products to more in-depth scrutiny.

Historically, SFSA has predominantly intervened in cases involving securities firms and advisors who sell high-risk products without considering consumer preferences. Given that insurance intermediaries often offer advice on packaged products, SFSA’s expanded focus on commissions and the mediation of particularly risky financial instruments is a natural progression of its 2021 review.

Expectations for Insurance Intermediaries

SFSA’s ongoing review covers 13 insurance intermediaries, which had an anticipated completion date before the summer of 2023. Following the review, SFSA is expected to place increased emphasis on intermediary oversight based on findings detailed in the report.

This emphasis will at least encompass:

  • The mediation of financial products within insurance solutions, especially to consumers.
  • Scrutiny of remuneration models.
  • Examination of conflicts of interest arising from remuneration models.
  • Assessment of the quality of advice and compliance with regulatory requirements.

In practice, this involves an extensive evaluation of the advisory process, including how companies inform, document, and archive information. It also encompasses intermediary training, internal regulations, routines, and processes.

Insurance intermediaries, especially those within the report’s scope, should prioritize internal compliance efforts. Conducting a GAP analysis can serve as an initial step to assess the current state of affairs, providing a basis for decision-making and prioritization.


The SFSA’s rigorous scrutiny of insurance intermediaries is a crucial step in bolstering consumer protection and maintaining the integrity of the financial services sector. As the audit unfolds, market players should closely monitor developments in this domain. The findings will likely have far-reaching implications for the industry, influencing how financial products are marketed, sold, and advised upon within the framework of insurance solutions. It’s a pivotal moment for insurance intermediaries to proactively address any potential issues and align their practices with evolving regulatory expectations.

For further inquiries or comments, please contact:

Robert Dahlström

Senior Manager

Filip Fabri

Senior Associate

[2] Financial Supervisory Authority (2021). Follow-up of the new rules on commission and independent advice (Dnr 21-31636
[3] Finansiella produkter med hög risk erbjuds konsumenter | Finansinspektionen

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