How Hong Kong insurance is regulated: the Insurance Authority, the Insurance Ordinance, key guidelines and intermediary licensing

Hong Kong's insurance industry is supervised by a single regulator, the Insurance Authority (IA). The IA is a statutory body independent of the government: it authorises and supervises insurers under the Insurance Ordinance (Cap. 41) and, since 2019, has licensed insurance intermediaries directly. Before 2017 insurers were supervised by a government department and intermediaries were registered by industry self-regulatory bodies; the current regime brings both under one statutory regulator.

Jurisdiction: Hong Kong. Rules that concern mainland residents are marked "Mainland China". This guide covers Hong Kong's own rules only; Hong Kong and Singapore comparisons are on our sister sites.

Regulators, legislation and the hierarchy of guidelines

According to a Hong Kong SAR Government press release (25 June 2017), the IA replaced the Office of the Commissioner of Insurance (OCI) as the regulator of insurers on 26 June 2017. The government described this as the most significant regulatory reform of the insurance industry since the Insurance Companies Ordinance was passed in 1983. That ordinance, as amended and renamed the Insurance Ordinance (Cap. 41), is the legal basis of the current regime.

Guidelines are not statutory provisions in themselves, but the IA uses compliance with them to judge whether insurers and intermediaries are "fit and proper", and a breach may lead to regulatory action. Formatting requirements such as illustration scenarios and Important Facts Statements all come from these guidelines.

Insurer authorisation and classes of long term business

Carrying on insurance business in Hong Kong requires IA authorisation. The schedules to the Insurance Ordinance divide insurance business into long term business and general business, and long term business is further split into classes. Those most relevant to individual life insurance readers are:

• Class A: life and annuity – traditional whole life, participating savings plans, term life, annuities and non-linked universal life mostly fall into this class;
• Class C: linked long term – products whose policy value is linked to chosen funds or an index, such as investment-linked assurance schemes (ILAS); indexed universal life (IUL) is also Class C;
• Class D: permanent health, among other classes.

The class determines which underwriting guideline applies: GL15 for Class C business and GL16 for long term business other than Class C. Readers can check which classes a company is authorised to write on the IA's Register of Authorized Insurers. The register also lists companies that are still authorised but have stopped accepting new business, so the number changes; rely on the latest entries on the IA register.

Intermediary licensing and register checks

Under the Insurance Companies (Amendment) Ordinance 2015, the IA took over from three self-regulatory organisations on 23 September 2019 and now regulates insurance intermediaries directly, covering licensing, inspection, investigation and discipline. Carrying on "regulated activities" by way of business (for example, arranging policies or giving regulated advice on insurance) requires an IA licence. As a transitional measure, anyone validly registered with the former bodies at that date was deemed licensed for three years (source: Mayer Brown, 17 September 2019).

The IA's consumer education website (last revised 29 August 2022) notes that only intermediaries licensed in Hong Kong may sell Hong Kong insurance products, and that consumers should check licence status on the Register of Licensed Insurance Intermediaries before using their services. When checking, confirm three things: the licence type (agent or broker), the line of business (whether it includes linked long term business) and the principal or firm the person is attached to.

Key guidelines that directly affect consumers

The table below lists the rules most directly relevant to buying a policy as an individual. Effective dates are compiled from IA documents or law firm commentary; rely on the latest versions on the IA website for the exact wording.

Several changes in the 2026 revision of GL16 are worth noting (according to DLA Piper, 25 March 2026): any change to bonuses or the bonus philosophy must be notified to policyholders "with clear reasons"; products with a premium offset arrangement must show a scenario in which bonuses are insufficient to offset premiums, and terms such as "vanishing premium" are prohibited; and products whose premiums can be adjusted during the payment term may not be labelled "level premium".

Levy, cooling-off period and complaint channels

Insurance levy: since 1 April 2021 the IA has collected a levy of 0.1% of premium, capped at HK$100 per policy year for long term policies and HK$5,000 for general insurance policies (source: IA press release, 31 March 2021). The levy is collected by the insurer together with the premium and is refunded if the policy is cancelled within the cooling-off period.

Cooling-off period: GL29 sets a cooling-off period of 21 calendar days for life policies, starting from delivery of the policy or issue of the cooling-off notice, whichever is earlier. VHIS Certified Plans also have a 21-day cooling-off period. If you surrender after the cooling-off period, the amount returned is based on the policy's cash value, which in the early years is usually far below the premiums paid.

Complaint channels: if you disagree with an insurer's decision, first use the company's internal complaint procedure; if the dispute remains, you can take it to the Insurance Complaints Bureau (ICB). Complaints about an intermediary's conduct can be made to the IA. For claim limits and time limits, see Claims, complaints and the Policy Holders' Protection Scheme.

A decade of Hong Kong insurance regulation (consumer view)

What regulation does and does not guarantee

The rules mainly govern three things: who may sell (insurer authorisation and intermediary licensing), how they sell (needs analysis, disclosure, cooling-off, place of signing) and how policies are managed after sale (participating fund governance, capital requirements, annual notices). These rules improve transparency, but there are several things the regulator does not promise:

1. Non-guaranteed benefits are not guaranteed. Fulfilment ratio disclosure and illustration caps simply let readers see "what was illustrated and what was delivered". Bonuses are still set by the insurer based on participating fund experience and can go up or down.
2. Insurer solvency is not underwritten. Hong Kong currently has no policyholder protection scheme covering life policies (for progress, see Claims and the PPS); the risk-based capital regime and the asset segregation required by GL34 are the main safeguards at present.
3. Mainland rules still apply. Foreign exchange controls and reporting of overseas income are governed by mainland rules; seek professional advice in your own jurisdiction.
4. "Authorised" is not a product endorsement. IA authorisation means a company may lawfully carry on business; it does not mean the IA endorses any product's returns or suitability.

If you would like help interpreting regulatory documents and policy terms in light of your own circumstances, you can register your needs through the contact details on this site.