Claims, complaints and the Policy Holders' Protection Scheme in Hong Kong: claim documents, the Insurance Complaints Bureau and PPS progress

A Hong Kong insurance claim is the process in which, after an insured event (death, diagnosis of a critical illness, hospitalisation and so on), the policyholder, life insured or beneficiary submits an application and supporting documents to the insurer, which then assesses the claim and pays the benefit. If you are unhappy with the outcome, Hong Kong offers three levels of recourse: the insurer's internal review, the Insurance Complaints Bureau and legal action. You should also know that Hong Kong currently has no Policy Holders' Protection Scheme (PPS) covering life policies; the legislation is still being prepared.

Jurisdiction covered: Hong Kong; document requirements for deaths or medical treatment in Mainland China are noted separately. Claim documents follow each insurer's current checklist.

Documents usually needed for three types of claim

The IA's consumer education website lists what a death claim generally needs: a claim form (completed by the claimant and the attending doctor), the original death certificate and a copy of the deceased's identity card, with the beneficiary also providing proof of identity and relationship. The basic structure for critical illness and medical claims is as follows:

The insurer may ask for further information during assessment or for authorisation to access medical records. Before submitting, it is sensible to copy every document and keep a record of the submission.

Extra requirements for deaths or treatment outside Hong Kong

Where the life insured dies outside Hong Kong, Hong Kong insurers generally ask for additional documents. Based on claims guidance published by several insurers (secondary; each insurer's own checklist prevails), common requirements include:

1. A notarised death certificate: for deaths in Mainland China, a notarial certificate of death is usually required.
2. Police or hospital certificates: such as the medical certificate of death issued by the hospital, or a police report where the death was not from natural causes.
3. Proof of deregistration: such as proof that the household registration has been cancelled; for Hong Kong Identity Card holders, a cancellation record from the Immigration Department may also be needed.
4. Certified translations: documents not in Chinese or English need a certified translation.

For critical illness or medical claims arising from treatment on the mainland, insurers usually ask for medical records, diagnoses and bills. Whether notarisation is required and whether particular hospitals are accepted depend on the policy terms. A Hong Kong and Singapore comparison of cross-border claims is on the sister site wholelife.hk.

Disclosure, waiting periods and claims disputes

Claims disputes most often arise from two sources: disclosure at application, and time limits in the policy terms.

• Duty of disclosure: the IA warns that "Any misrepresentation or non-disclosure may affect future claims or even invalidate your policy". Questions on medical history, occupation and lifestyle in the application form should be answered factually; if unsure, ask the insurer in writing.
• Critical illness waiting period: the IA's critical illness insurance leaflet states that the waiting period is generally 60 to 90 days after the policy takes effect, and can be as long as 180 days or one year for some illnesses; it may restart on reinstatement or when the sum insured is increased (subject to the policy terms).
• Survival period: generally 14 to 30 days after diagnosis or surgery; the life insured must survive to the end of this period to qualify for payment.
• Interval between multiple claims: multiple-claim critical illness policies generally set a further waiting period of one to five years between claims.

Critical illness and medical policy terms are explained in detail on critical illness and medical insurance; completing the application form is covered on the application and underwriting process.

Complaint routes and the Insurance Complaints Bureau (ICB)

The IA states clearly that "the IA is not empowered to handle disputes about claims". If you disagree with a claims decision, take the following steps in order:

ICB eligibility conditions (subject to the ICB's current terms of reference):

1. The amount in dispute does not exceed HK$1,500,000.
2. The complaint must be made within six months of the date of the insurer's final decision.
3. Only personal policies are covered, not commercial, group or third-party insurance.
4. Non-Hong Kong residents may complain, provided the policy was issued by an ICB member insurer.
5. The service is free; average handling time is about four to six months, and complex cases may take longer.

According to the ICB briefing, Complaints Panel rulings are binding on member insurers; if the complainant does not accept a ruling, their legal rights are not affected. Intermediary conduct issues (such as mis-selling) can be reported separately to the IA.

Progress on the Policy Holders' Protection Scheme (PPS)

The PPS is a statutory scheme that would pay policyholders a degree of compensation if an insurer became insolvent. Progress in Hong Kong is as follows:

The final compensation formula and cap have not been decided, so any claim that "the PPS will pay a given percentage" currently has no legal basis. According to Legislative Council papers, the three insurer insolvencies in Hong Kong since the late 1990s all involved small and medium-sized general insurers, and no long term insurer has become insolvent. This does not mean the risk is zero, nor that the government stands behind policies. Existing protection comes mainly from the IA's capital requirements (the risk-based capital regime, implemented on 1 July 2024) and the governance rules for participating funds; see how Hong Kong insurance is regulated.

The Greater Bay Area after-sales service centre and cross-border servicing

Setting up an insurance after-sales service centre in the Guangdong-Hong Kong-Macao Greater Bay Area, so that mainland policyholders could handle claims and policy servicing closer to home, has been under policy discussion for years. As at October 2026, this site has seen no official announcement that it is formally in operation. Readers should assume that claims and policy servicing still follow the insurer's procedures in Hong Kong, and that some matters may require original documents to be posted or the policyholder to attend in person.

Use this checklist to prepare before making a claim:

1. Ask the insurer for its latest claims checklist and forms, and confirm the submission deadline.
2. Prepare originals and certified copies of proof of identity, relationship and the event; have documents from outside Hong Kong notarised and translated first.
3. Keep records of every submission and all correspondence.
4. If you receive a rejection or partial payment notice, ask for the reasons in writing and note the six-month deadline for complaining to the ICB.

Signing and after-sales arrangements for mainland visitors are covered on mainland visitors buying insurance in Hong Kong. If you need these points interpreted for your own circumstances, you can register your enquiry through the contact details on this site.