Insurance: authorisations, reports and contracts · France / Switzerland
Insurance portfolio transfer: perimeter and approval dossier
An insurance portfolio transfer first defines policies, liabilities and territorial risks, then examines the receiving undertaking. France and Switzerland have different approval, publication and policyholder-protection procedures. Gather permissions, prudential records and actual notices before determining the operation’s effect. A transfer agreement alone does not establish every effect against insured parties. Moving insurance contracts is distinct from a competition-law change of control of the insurer itself.
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Sources checked3 November 2026
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Who receives them and what permissions cover the activity?
France: reconcile the receiving insurer’s permission with L324-1’s actual transfer conditions. Switzerland: connect the receiver and FINMA operating scope likewise; permission for one class does not prove coverage of every transferred activity.
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Which policies, liabilities and territorial risks enter the transfer?
France: define policies, liabilities, classes and territories in the proposed portfolio. Switzerland: identify the corresponding Swiss transfer perimeter; a share sale or commercial list does not establish the actual contracts being transferred.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Portfolio-perimeter, recipient and approval preparation dossier
Synthetic example: fictional records. Portfolio-perimeter, recipient and approval preparation dossier.
Synthetic example: fictional records · Portfolio-perimeter, recipient and approval preparation dossier
- Jurisdiction
- France
- Portfolio and policies
- Perimeter P1, policies C1
- Transferor and recipient
- Undertakings A1 and A2, permissions T1
- Protection and prudence
- Evidence S1, review R1
- Procedure and decision
- Publication N1, approval D1
Moving insurance contracts is distinct from a competition-law change of control of the insurer itself.
Who receives them and what permissions cover the activity?
France: reconcile the receiving insurer’s permission with L324-1’s actual transfer conditions. Switzerland: connect the receiver and FINMA operating scope likewise; permission for one class does not prove coverage of every transferred activity.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Preparation reference: Portfolio-perimeter, recipient and approval preparation dossier
| Preparation question | Point to verify |
|---|---|
| Which policies, liabilities and territorial risks enter the transfer? | France: define policies, liabilities, classes and territories in the proposed portfolio. Switzerland: identify the corresponding Swiss transfer perimeter; a share sale or commercial list does not establish the actual contracts being transferred. |
| Who receives them and what permissions cover the activity? | France: reconcile the receiving insurer’s permission with L324-1’s actual transfer conditions. Switzerland: connect the receiver and FINMA operating scope likewise; permission for one class does not prove coverage of every transferred activity. |
| What evidence protects policyholders and creditors? | France: retain policyholder and creditor protection evidence rather than an unsupported continuity statement. Switzerland: VAG Article 62 requires its own insured-interest assessment; proposed protections and approved conditions must remain separate records. |
| Which solvency and risk records support the operation? | France: connect prudential evidence and relevant periods to the operation. Switzerland: retain corresponding capital and risk documentation without recalculating eligibility; one certificate or number alone does not establish every approval condition. |
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
What evidence protects policyholders and creditors?
France: retain policyholder and creditor protection evidence rather than an unsupported continuity statement. Switzerland: VAG Article 62 requires its own insured-interest assessment; proposed protections and approved conditions must remain separate records.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Which solvency and risk records support the operation?
France: connect prudential evidence and relevant periods to the operation. Switzerland: retain corresponding capital and risk documentation without recalculating eligibility; one certificate or number alone does not establish every approval condition.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
What application, publication and observation procedure applies?
France: L324-1 distinguishes application, publicity and observations within its framework. Switzerland: establish the actual FINMA submission and communication procedure separately; a French publication timetable must not be treated as a universal Swiss clock.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Which official provision helps explain this situation?
An insurance portfolio transfer first defines policies, liabilities and territorial risks, then examines the receiving undertaking. France and Switzerland have different approval, publication and policyholder-protection procedures. Gather permissions, prudential records and actual notices before determining the operation’s effect. A transfer agreement alone does not establish every effect against insured parties. Moving insurance contracts is distinct from a competition-law change of control of the insurer itself.
Which approval gives the transfer its relevant effect?
France: reconcile approval, publication and legal-effect evidence under the relevant branch. Switzerland: retain actual FINMA decision, conditions and effective date; signing the business agreement does not prove the portfolio transfer is already effective.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
What information or termination rights need separate examination?
France: verify the operation’s actual information and termination rights without a universal promise. Switzerland: Article 62 includes conditional insured-rights branches; the transfer does not automatically establish the same termination outcome for every policyholder.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Why is contract transfer different from a competition-law change of control?
France: moving policies differs from corporate control or merger notification. Switzerland: likewise distinguish portfolio transfer and sale of the insurer; approval in one framework does not demonstrate every permission in the other.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Which official references should you consult?
- ACPR portfolio transfer procedureacpr.banque-france.fr
- Code assurances L324-1 : L324-1www.legifrance.gouv.fr
- Insurance Supervision Act LSA/VAG/LSA : 62fedlex.data.admin.ch
- Insurance Supervision Act LSA/VAG/LSA : 62fedlex.data.admin.ch
- Insurance Supervision Act LSA/VAG/LSA : 62fedlex.data.admin.ch
Texts cited last checked: 3 November 2026
What other questions arise in this file?
Who receives them and what permissions cover the activity?
France: reconcile the receiving insurer’s permission with L324-1’s actual transfer conditions. Switzerland: connect the receiver and FINMA operating scope likewise; permission for one class does not prove coverage of every transferred activity.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Which solvency and risk records support the operation?
France: connect prudential evidence and relevant periods to the operation. Switzerland: retain corresponding capital and risk documentation without recalculating eligibility; one certificate or number alone does not establish every approval condition.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Which approval gives the transfer its relevant effect?
France: reconcile approval, publication and legal-effect evidence under the relevant branch. Switzerland: retain actual FINMA decision, conditions and effective date; signing the business agreement does not prove the portfolio transfer is already effective.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62
Why is contract transfer different from a competition-law change of control?
France: moving policies differs from corporate control or merger notification. Switzerland: likewise distinguish portfolio transfer and sale of the insurer; approval in one framework does not demonstrate every permission in the other.
ACPR portfolio transfer procedureCode assurances L324-1 : L324-1Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62Insurance Supervision Act LSA/VAG/LSA : 62