SWEDEN Trends and Developments Contributed by: Viveka Classon, Karin Rättzén and Sara Stålebring, Advokatfirman Vinge KB
accurate and detailed disclosure of building charac- teristics. In parallel, the industry is working to update regula- tions and practices to reduce risks and align construc- tion methods with insurance requirements, supported by Insurance Sweden and the relevant authorities. Challenges remain for the existing building stock, and brokers are increasingly seeking international capacity solutions, including via Lloyd’s, for assets that Swed- ish insurers assess as higher risk. Supervisory Focus Increased supervisory focus on the market for transfers of pension insurance policies After two years of strong growth in the volume of transfers of occupational pension insurance, this volume declined during the second half of 2025. It remains high, however: according to Insurance Swe- den, a total of just over SEK22 billion was transferred in the third quarter of 2025. Unit-linked and deposit insurance are transferred to a greater extent than traditional insurance policies. The high transfer volume has prompted the SFSA to focus on the developments on the market for transfers of pension insurance policies. In the SFSA’s Consumer Protection Report 2025, the SFSA warns against unwarranted transfers that are not driven by the consumer’s best interest, and, in some situations, is not comprehensible for the insured individual. According to the SFSA, there is a risk that financial firms, advisors and other parties are recom- mending that customers transfer their occupational pension for reasons other than the policyholder gain- ing access to a better pension. Such situations include, for example, the insured party being offered a transfer of pension insurance in connection with applying for a mortgage, and a lower loan interest rate if agreeing to transfer the insurance to an insurer in the same group as the bank. In the report, the SFSA indicated that it would look more closely into the transfer of occupa- tional pensions and how this impacts consumers. In October 2025, the SFSA initiated an in-depth anal- ysis of four major life insurance companies to gain a deeper understanding of the risks associated with
transferring collectively agreed occupational pension plans. Further, in a report published in June 2025, the SFSA emphasised the importance of insurance inter- mediary firms having procedures for identifying and managing conflicts of interest that could arise within their operations, in particular in relation to transfers of insurance. Suitability, Value for Money and Distribution Conflicts of Interests One of the areas of supervisory focus for the SFA dur- ing 2025 was poor and unsuitable insurance prod- ucts. According to its Consumer Protection Report 2025, the SFSA will intensify the supervision of sav- ings products in general, including wrapped insurance products. The SFSA has indicated that Sweden’s life insurance market continues to grapple with complex savings and insurance products – both within insurance wrap- pers and sold alongside them – where suitability, cost transparency, and value for money are under scrutiny. SFSA findings indicate that products such as auto- calls, credit-linked notes, certain listed alternative investment funds, and some capital insurance offer- ings carry fee levels and structural complexity that many retail customers struggle to understand, under- mining expected returns and raising questions about appropriateness. High and layered charges – prod- uct, distribution, and advisory – can erode outcomes, while “value for money” concerns persist when prod- uct features do not match what customers are paying for, including sustainability claims, purported active management, and overlapping cover in product and payment protection insurance. The SFSA also states that conflicts of interest in commission-based distribution remain a key risk, with incentives that can skew recommendations toward expensive or unsuitable products and a still-limited
independent advisory segment. Unnecessary Insurance Products
The SFSA has a continued focus of demands-and- needs assessments, conflicts of interest, and loan/ payment protection insurance within the broader con- text of insurance distribution and consumer protec-
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