SWITZERLAND Law and Practice Contributed by: Jodok Wicki, Daniel Zemp, Fabienne von Moos and Doruntina Dembogaj, CMS von Erlach Partners Ltd
legislation would go further by introducing binding obligations with a broader scope of application. Nature-Related Financial Risks and Intermediary Regulation FINMA’s Circular 2026/1 on nature-related financial risks entered into force on 1 January 2026, setting supervisory expectations for insurers to identify, assess and manage material climate- and nature- related financial risks. The circular applies in stages: initially to climate-related financial risks from 2026 and to all nature-related financial risks from 2028. These developments may influence policy wordings where climate-risk assumptions feed into pricing, exclusions or reserving, but the outlook is incremental guidance rather than a new insurance contract code.
241 I NSURANCE L I T IGATI O N 2026
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