Sales partners are responsible for an average of 55 per cent of total pension insurance sales across Finland’s four major earnings-related pension companies, according to a recent review by the Finnish Financial Supervisory Authority (FIN-FSA).

The findings underline the significant role played by external partners in the distribution strategies of Varma, Ilmarinen, Elo, and Veritas.

The FIN-FSA’s assessment focused on the extent to which these partners contribute to customer acquisition and marketing activities, the level of control delegated to them, and how the companies manage associated risks.

Each company was found to rely on one to four significant sales partners – typically large financial institutions, such as life or non-life insurers or banks – to promote both employees' (TyEL) and self-employed individuals' (YEL) insurance products through online, telephone, and face-to-face channels.

While the partners play a key role in driving new business and managing client relationships, the FIN-FSA confirmed that they “do not exercise any decision-making power” in the establishment of pension insurance contracts.

All final decisions remain firmly with the pension insurers, in line with legal and regulatory requirements.

The review, which was based on financial statements, sales reports, internal audit material, and publicly available information, found that each IORP had incorporated sales partner risks into their business and operational risk frameworks. Internal controls were in place across all firms, with partner relationships subject to oversight mechanisms.

The supervisory authority highlighted good practices observed during the review, including regular assessments of partner management models and efforts to adapt internal controls to evolving market conditions.

It also emphasised the need for comprehensive and ongoing training of sales partners, ensuring that outsourced activities align with regulatory expectations and good insurance practice.

No regulatory breaches or deviations from FIN-FSA guidance were identified. As part of its ongoing supervisory work, the authority will continue to provide firm-specific feedback and monitor developments in the governance and oversight of partner relationships within the occupational pensions sector.

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