Interim legal and compliance in insurance

Short answer: Insurers mainly need legal project support for product development and product approval, changes in distribution rules, outsourcing and ICT contracts, implementing new supervisory requirements, and vacancies in legal or compliance. In Germany, Section 29(1) of the Insurance Supervision Act (VAG) requires a compliance function within the internal control system, and Section 32(1) VAG makes clear that an insurer remains responsible for all supervisory requirements when it outsources; in Switzerland, FINMA supervises insurers under the Swiss Insurance Supervision Act (ISA/VAG). For peaks and projects, an interim insurance lawyer or compliance professionals can be brought in, part-time or full-time.

This guide is for general counsel, heads of legal and heads of compliance at primary insurers, reinsurers, health insurers and insurance intermediaries in Switzerland and Germany. It shows typical projects, the matching roles and what supervision, product rules and distribution rules require.

Which projects do insurers run? Project type and role

Insurers continuously run projects that tie up legal and compliance capacity. The table shows the most common project types and the matching role.

Alpinum Solutions provides these roles through staff leasing or freelancing, part-time or full-time, as individuals or teams. Insurance and reinsurance is one of the sectors in which Alpinum has completed assignments over the last 24 months. Relevant profiles are described under insurance and regulatory law.

Supervision: FINMA and BaFin

Insurers in both countries are closely supervised, with requirements on organisation, compliance and outsourcing.

For insurers with business in both countries, projects often have to cover two supervisory regimes in parallel. Interim lawyers with experience of both are therefore in particular demand.

Product and distribution law: what insurance lawyers review

Product and distribution law is the core area for many insurance lawyers. It covers policy terms, customer information, product approval and the rules for distribution.

Product approval in Germany

Under Section 23(1a) VAG, insurers that design products must maintain an internal approval process for each product and each significant change, and define a target market before distribution. Section 23(1b) VAG requires regular review of whether the product and distribution strategy still fit the target market. These provisions do not apply to large risks or to reinsurers (Section 23(1d) VAG).

Distribution in Switzerland

In Switzerland, the revised VAG and AVO have applied since 1 January 2024; according to FINMA, this has raised the requirements for insurers' distribution activities. Insurers may not work with unbound intermediaries who are not registered (Art. 44(2) VAG) and must ensure duties towards customers are met, such as customer information under Art. 45 VAG. FINMA set out its expectations of insurers working with tied and untied intermediaries in Guidance 05/2024 of July 2024.

Typical project tasks

• Drafting or revising general policy terms and conditions.
• Reviewing customer information and application forms.
• Documenting the product approval process and writing target market descriptions.
• Reviewing intermediary and cooperation agreements, for example with banks or platforms.
• Preparing training for sales and customer service on new rules.

Outsourcing and ICT contracts

Outsourcing and ICT contracts are a constant topic for insurers because supervision and contract reality are closely linked. In Germany, Section 32(2) VAG requires an insurer to ensure, among other things, that it, its auditor and the supervisor have access to all relevant data and that the supervisor has access rights to the service provider's premises.

A typical project runs in five steps:

1. Build an inventory: record all outsourcing and ICT contracts with provider, service, criticality and term.
2. Set the requirements: a checklist drawn from the VAG, FINMA requirements and, where relevant, DORA.
3. Gap analysis: review each contract against the checklist and document gaps.
4. Renegotiation: draft amendments and agree them with providers, prioritised by criticality.
5. Register and handover: maintain results in the outsourcing or information register and hand over to the business.

The guide on DORA legal and compliance workstreams shows which work packages DORA brings for legal and compliance.

Profiles: what insurance lawyers and compliance professionals should bring

A good interim profile for an insurer combines insurance law with knowledge of supervision and internal processes. These criteria help with selection:

• Line of business: life, non-life, health or reinsurance; the questions differ considerably.
• Supervisory regime: experience with FINMA, BaFin or both.
• Focus: products and terms, distribution, outsourcing and IT, governance, or claims and litigation.
• Languages: depend on the line of business, the client base and the working environment; state them in the role profile.
• Seniority: senior for project leadership and supervisor contact, experienced for contract and policy-terms work, junior for inventories and analysis within a team.

Under staff leasing the insurer holds the right to give professional instructions and the professional is integrated into its organisation; under freelancing the professional works independently within the agreed mandate. The guide on building a compliance management system covers how to set up or refresh a compliance programme.

Limits and risks

• Responsibility stays with the insurer: key functions and responsibilities towards the supervisor sit with the company and its governing bodies.
• Formal functions: professionals can take on formal functions such as a compliance officer with regulatory responsibility, through staff leasing or freelancing. In Germany, the intended appointment of a person responsible for a key function such as compliance must be notified to BaFin without delay, and the person must be reliable and professionally qualified (section 47 no. 1 and section 24(1) VAG). Whether filling the role in Switzerland triggers a notification or approval duty towards FINMA is for the insurer to clarify before the start with FINMA or its audit firm.
• No legal advice from Alpinum: Alpinum is not a law firm; opinions and representation stay with law firms.
• Confidentiality: health and claims data are especially sensitive. Access rights and a confidentiality agreement belong in onboarding.

Frequently asked questions about interim legal and compliance in insurance

What makes insurance compliance different?

Insurance compliance combines supervisory law, product law and distribution law. In Germany the compliance function is part of the internal control system under Section 29(1) VAG; in Switzerland FINMA sets requirements on governance and risk management. On top come product approval, intermediary oversight, outsourcing and the protection of health and claims data.

What legal projects do insurers run?

Typical projects are product development and revision of policy terms, changes in distribution rules, review of outsourcing and ICT contracts, implementation of new supervisory requirements, portfolio migrations and disputes. Many have fixed deadlines and a high volume of similar documents, which makes them a good fit for interim teams.

Do interim lawyers need insurance sector experience?

For policy terms, product approval and supervisory topics, sector experience is a clear advantage because the language, processes and supervisory logic are specific. For reviewing IT and service provider contracts, experience from other regulated sectors such as banking is often enough, supported by the insurer's checklist and an experienced contact person.

What does Section 32 VAG require for outsourcing?

Section 32(1) VAG makes clear that an insurer that outsources functions or insurance activities remains responsible for all supervisory requirements. Under paragraph 2, outsourcing must not impair proper performance, management's ability to steer and control, or the supervisor's audit rights. The contract must secure data access and the provider's cooperation.

How quickly can an interim insurance lawyer be found?

At Alpinum, selected profiles are usually available within 48 hours; the insurer and Alpinum agree the start date together. A precise role profile stating line of business, supervisory regime, languages and workload speeds up selection.

Next step

Tell us about the project type, line of business, supervisory regime and timeline. We will show you suitable legal or compliance profiles for your insurance business.

• Insurance and regulatory law
• Interim compliance
• Building a compliance management system
• Discuss your requirements

Last updated: 31 October 2026.