Based on the Insurance Ordinance (Cap. 41) and the latest IA circular

Hong Kong insurance intermediaries
Complete Guide to License Application

Insurance Brokerage Firms, Insurance Agencies, and Individual Licensees—A Comprehensive Guide from Qualification Exams to Continuous Compliance

The Insurance Authority (IA) of Hong Kong implemented a statutory insurance intermediary licensing system on September 23, 2019. This system is frequently searched as "Hong Kong insurance license," "Hong Kong insurance intermediary license," or "Hong Kong insurance broker license." In English, it includes terms like "Hong Kong insurance intermediary license," "insurance intermediary license Hong Kong," and "Hong Kong insurance broker license." As of February 2026, there are over 120,000 licensed individual insurance intermediaries in Hong Kong, with premium income continuing to grow.The Hong Kong Insurance Authority (IA) has implemented the statutory insurance intermediary licensing regime since 23 September 2019. This page supports Hong Kong insurance intermediary license, insurance intermediary license Hong Kong, Hong Kong insurance broker license, Hong Kong insurance agency license, insurance license application Hong Kong, insurance broker license application, IA license Hong Kong and Insurance Authority Hong Kong search intent. It helps teams compare insurance broker, insurance agency and individual intermediary licensing requirements, fees, examination and ongoing compliance obligations.

120,947

Licensed individual insurance intermediaries (as of February 2026)

808

Licensed insurance brokerage firm

6,370 billion+HKD 637+ billion

Premium income for the first three quarters of 2025 (HK$)

Current Status of the Hong Kong Insurance Intermediary Market

From self-regulation to statutory licensing—Regulatory upgrade in one of the world's largest cross-border insurance markets

120,947

Total number of licensed individual intermediaries

IA official statistics (February 28, 2026)

83,613

Licensed personal insurance agent

IA official statistics

23,478

Licensed business representative (agent)

IA official statistics

13,856

Licensed business representative (broker)

IA official statistics

1,479

Licensed insurance agency

IA official statistics

808

Licensed insurance brokerage firm

IA official statistics

~ 160

Recognized insurer

IA official statistics

HK$829 billion (+10.5%)HKD 82.9 billion (+10.5%)

Gross premium for general business in the first three quarters of 2025

IA official statistics

HK$5,541 billion (+36.6%)HKD 554.1 billion (+36.6%)

Premiums for long-term in-force business in the first three quarters of 2025

IA official statistics

Confirmed

The above data comes from official statistics from the IA.

Based on the original text of Cap. 41 and the content explicitly stated in the IA's official guidelines/circuits.

Timeline —

Before 2010

Insurance agents are subject to self-regulation by insurers, while brokers are subject to self-regulation by PIBA/CIB.

June 2015

The revised Insurance Company Ordinance was passed, establishing a licensing system for statutory insurance intermediaries.

June 2017

The Insurance Authority (IA) was formally established, replacing the Insurance Commissioner's Office.

September 23, 2019

The statutory insurance intermediary licensing system has been officially implemented, with a four-year transition period beginning.

December 31, 2023

Upon completion of the transition period, all intermediaries must convert to IA licenses.

January 1, 2024

Financial requirements for insurance brokerage firms have come into full effect (paid-in capital of HK$50, PII, etc.).

September 23, 2024

IA begins charging license fees (free during the transition period).

June 2025

New regulations take effect

Joint Circular between the IA and HKMA: IUL is classified as Class C, for professional investors only.

August 1, 2025

New regulations take effect

The person in charge must complete an additional 2 hours of management duties as a CPD.

October 1, 2025

New regulations take effect

Referral fees must not exceed 50% of the total commission.

January 1, 2026

New regulations take effect

Commission sharing system for participating policies takes effect (≤70% in the first year) + Background check program launched

Mainland Visitor Insurance (MCV) policies continue to grow

Long-term business premiums grew by 36.6% in the first three quarters of 2025, with MCV policies being the main driver.

horizontal1

Stricter regulations

IA strengthens crackdown on unlicensed referral activities, reforms commission transparency, and enforces AML compliance.

The Rise of InsurTech

JD.com obtains insurance brokerage license (October 2025), accelerating the development of digital channels.

Global 1

Cross-border compliance becomes more complicated

New challenges include VA insurance products, IUL regulatory classification, and cross-border referral regulations.

Section 64ZZB of the Insurance Ordinance (Cap. 41):

No one may act as an insurance intermediary unless that person is licensed under this Department.

Confirmed

Source: Insurance Ordinance, Cap. 41, Section 64ZZB

Insurance intermediary license classification

6 license types × 6 business scopes — Find the license combination that best suits you

Licensed personal insurance agent

Licensed Individual Insurance Agent

Appointee

Approved insurer (directly appointed)

Representing interests

insurer

Number of licensees

83,613

Validity period

1 year / 2 years / 3 years (optional)

IIQE requirements

Volume 1 + Related Business Volume

Licensed business representative (agent)

Licensed Technical Representative (Agent)

Appointee

Licensed insurance agency

Representing interests

Insurer (through an agent)

Number of licensees

23,478

Validity period

1 year / 2 years / 3 years (optional)

IIQE requirements

Volume 1 + Related Business Volume

Licensed business representative (broker)

Licensed Technical Representative (Broker)

Appointee

Licensed insurance brokerage firm

Representing interests

Client (through a brokerage firm)

Number of licensees

13,856

Validity period

1 year / 2 years / 3 years (optional)

IIQE requirements

Volume 1 + Related Business Volume

Contrast Dimensions Licensed insurance agency Licensed insurance brokerage firm
English name Licensed Insurance Agency Licensed Insurance Broker Company
Whose interests are represented? insurer Client (independent of the insurer)
Current number of licenses 1,479 808
Licence validity period 3 3
Minimum paid-in capital No legal requirements HK$500,000
Minimum Net Assets No legal requirements HK$500,000
Professional Indemnity Insurance (PII) No legal requirements Must purchase (>2 times annual insurance brokerage gross income)
Customer Account No legal requirements Must maintain a separate customer account with a Hong Kong bank
Audited financial statements No legal requirements Annual submission required
A liar At least one person approved by the IA must be appointed as the person in charge. At least one person approved by the IA must be appointed as the person in charge.
Application processing time 12 week 12 week

Responsible Officer

Each licensed insurance agency and insurance brokerage firm must appoint at least one Officer of the Insurance Authority (RO) to oversee and manage the regulated activities of the agency/firm.

Identity requirements
Must be a director or partner of the institution/company

Suitable person
Must be assessed by an appropriate candidate from the IA

IIQE
Must pass the IIQE-related exam (or obtain an exemption)

New requirements for CPD
From 1 August 2025, the responsible person must complete an additional 2 hours of CPD on management responsibilities, counted within the ethics/regulatory category and the overall 15-hour requirement.

New regulations take effect

Approval time
4 weeks

cost
HK$1,800/time

Business categories Explain IIQE requirements
General insurance businessGeneral insurance business Property, liability, marine, accident and other non-life insurance Volume 1 + Volume 2
Long-term insurance business (excluding investment-linked insurance) Life insurance, annuities, retirement plans, etc. (excluding investment-linked insurance) Volume 1 + Volume 3
Long-term insurance business (including investment-linked insurance) Including investment-linked insurance products Volume 1 + Volume 3 + Volume 5
General + Long-term (excluding investment-linked contracts) Comprehensive services Volume 1 + Volume 2 + Volume 3
General + Long-term (including investment-linked) The most comprehensive business scope Volume 1 + Volume 2 + Volume 3 + Volume 5
Restricted scope of travel insurance business Travel insurance agents only Volume 1 + Volume 6

Register of Licensed Insurance Brokers

Inquiry and Verification – Guide to Using the IA Official List and Register of Licensed Brokers

Overview of the number of licensed intermediaries

83,613

Licensed personal insurance agent

23,478

Licensed business representative (agent)

13,856

Licensed business representative (broker)

1,479

Licensed insurance agency

808

Licensed insurance brokerage firm

Shield 1

~ 160

Recognized insurer

Confirmed

Data source: Official statistics from the International Asylum Authority (as of February 28, 2026)

Based on the original text of Cap. 41 and the content explicitly stated in the IA's official guidelines/circuits.

How to check license status

Demand analysis and consulting

Visit the IA Official Register

Go to the Register of Licensed Insurance Intermediaries on the website of the Insurance Authority (IA).

Signing Mou and launching an investigation

Select query type

You can search by category: individual intermediary, insurance agent, or insurance brokerage company.

Complete the investigation and sign the Spa

Enter search criteria

Enter name/company name, license number, or business category to search.

Regulatory applications and approvals

View license details

View information such as license validity period, business scope, appointed insurers, and disciplinary records.

Check the IA Register of Licensed Realtors View IA Register page

Recent developments of well-known licensed institutions

JD.com

Obtained IA Insurance Broker License in October 2025
A landmark event in the entry of mainland Chinese tech giants into the Hong Kong insurance market.

CompareAsia Group

Licensed insurance brokerage firm
Asia's leading fintech comparison platform

bowtie

Licensed Virtual Insurance Company
Hong Kong's first purely online insurance company (with an accredited insurer's license, not a brokerage license).

The Insurance Authority's Register of Licensed Insurance Intermediaries is a publicly accessible system where anyone can check an intermediary's licensing status, scope of business, and disciplinary record free of charge. It is recommended to verify an insurance intermediary's licensing status through the register before engaging with them.

Who needs an insurance broker license?

Scope of application and exemption arrangements under the statutory licensing system

Overview of the number of licensed intermediaries

shopping cart

Selling insurance products

Promoting, selling, or arranging insurance contracts to customers

Insurance brokerage services

Representing clients in negotiating insurance terms and premiums with insurers. If operating as a Hong Kong insurance brokerage firm, it is usually necessary to assess the application requirements for a Hong Kong insurance broker license.

Insurance claims assistance

Assisting clients with insurance claims

Rotate 1

Insurance renewal arrangements

Arrange for the renewal of existing policies

Share 1

Referral activities

Refer potential clients to licensed intermediaries (if regulated activities are involved).

Exempted entities

Recognized insurer

Insurance companies themselves do not need intermediary licenses.

Bank (Authorized Institution)

Bank (Authorized Institution)

Regulated by the HKMA, insurance products are sold through banking channels.

MPF intermediary

MPF intermediary

MPF intermediaries regulated by the Mandatory Provident Fund Schemes Authority

Article 79 Exemption

IA may grant specific exemptions on a case-by-case basis (application fee HK$20,000).

09 Warning
Operating an insurance intermediary business without a license is a criminal offense.

According to Section 64ZZB of the Insurance Ordinance, any person who acts as an insurance intermediary without a license is liable on conviction to a fine of HK$100,000 and imprisonment for 2 years.

Confirmed

Based on the original text of Cap. 41 and the content explicitly stated in the IA's official guidelines/circuits.

Insurance Broker vs. Insurance Agent: Core Positioning Differences

Choosing the right license type is the first step to business success.

Contrast Dimensions Insurance Agent Insurance Broker
Who does it represent? Insurer (Insurance Company) Customer (policyholder)
Legal Relationship Insurer's Agent The client's agent
Product range Products limited to appointed insurers Compare products from multiple insurers
independence Instructions from the insured Independent of the insurer
Commission source Insurer pays The insurer makes the payment (but must disclose this to the customer).
Customer Account No requirement Independent customer accounts must be maintained.
PII Insurance No requirement Must purchase
Financial requirements lower Paid-in capital ≥ HK$50 + Net assets ≥ HK$50
Who is it suitable for? Teams that establish in-depth cooperation with specific insurers Professional organizations that provide independent comparison and consulting services

Licensed insurance companies broker must comply with the Insurance (Financial and Other Requirements for Licensed Insurance Broker Companies) Rules (Cap. 41L), including minimum paid-up share capital, net asset, professional indemnity insurance and client account requirements. These requirements became fully effective on 1 January 2024, and the four-year transition period ended on 31 December 2023.Licensed insurance broker companies must comply with the Insurance (Financial and Other Requirements for Licensed Insurance Broker Companies) Rules (Cap. 41L), including minimum paid-up share capital, net asset, professional indemnity insurance and client account requirements. These requirements became fully effective on 1 January 2024, and the four-year transition period ended on 31 December 2023.

Confirmed

Based on the original text of Cap. 41 and the content explicitly stated in the IA's official guidelines/circuits.

Insurance intermediary license application requirements

Six major categories—from qualification exams to comprehensive assessment of suitable candidates

Examination subjects Volume Number Application Passing score
Insurance Principles and PracticesPrinciples and Practice of Insurance Volume OneVolume One A must-know exam for all intermediariesRequired for all intermediaries 70 %
General InsuranceGeneral Insurance Volume TwoVolume Two General insurance businessGeneral insurance business 70 %
Long-term insuranceLong-term insurance Volume ThreeVolume Three Long-term insurance businessLong-term insurance business 70 %
Investment-linked long-term insuranceInvestment-linked Long-term Insurance Volume FiveVolume Five Unit-linked insurance businessUnit-linked insurance business 70 %
Limited scope of travel insuranceLimited-scope Travel Insurance Volume SixVolume Six Travel insurance agentTravel insurance agents 70 %

The examination is administered by the Vocational Training Council (VTC).

Those holding relevant professional qualifications may apply for exemption from certain examinations.

Exam language: Chinese or English

Exam format: Multiple choice questions (75 questions/paper)

Results are valid for 2 years from the date of passing the first paper.

Education level and qualifications

IIQE qualification, relevant academic qualifications, professional certifications

Relevant experience

Work experience in the insurance or financial services industry

Character and Integrity

No criminal record, no bankruptcy record, no disciplinary record

financial condition

No outstanding judgment debts, sound financial condition

Abilities and Competencies

Understanding insurance products and supervision requirements

Continuous compliance record

Past compliance performance and CPD completion status

Requirement Category Specific standards
Minimum paid-in capital HK$500,000 (must be maintained continuously)
Minimum Net Assets HK$500,000 (must be maintained continuously)
Professional Indemnity Insurance (PII) Minimum compensation limit = 2 times annual gross income of insurance brokers
PII Deductible Limit Not exceeding 50% of net assets
Customer Account Must maintain a separate customer account with a Hong Kong bank
Audited financial statements An annual report is required, disclosing commission income, customer account balances, etc.
A liar ≥1 RO approved by the IA (must be a director or partner)
Requirement Category Specific standards
Company registration Must be a Hong Kong registered company
Insurer Appointment Must be appointed by at least one recognized insurer
A liar ≥1 IA-approved RO
Internal control A compliance management system must be established.
AML/CFT Anti-money laundering policies and procedures must be developed.
Requirement Category Specific standards
appoint Must be appointed by the insurer/agent/brokerage firm
IIQE Through Volume 1 + related business volumes (or with exemption)
age ≥18 years old
Suitable person IA appropriate candidate assessment
Education High school graduation or equivalent (minimum requirement)
Requirement Category Specific standards status
Identity Must be a director or partner of the institution/company
IIQE Pass the relevant exam (or obtain an exemption)
experience Typically, ≥3 years of insurance industry management experience is required. To be confirmed
Suitable person IA appropriate candidate assessment
CPD At least 15 hours per year; from August 2025 onward, an additional 2 hours of CPD on management responsibilities is required, counted within the ethics/regulatory category and the 15-hour total. New regulations take effect
Approval time 4 week
cost HK$1,800/session

Unsure which type of insurance broker license is required?

Broker or agent? Individual or organization? Aiying's compliance team offers free license type assessment and application roadmap planning.

Schedule a free evaluation

Insurance intermediary license application process

From preparing teaching materials to obtaining a license—a categorized process guide

Demand analysis and consulting

Step 1: Through IIQE

1-3 months

Register and pass the exam consisting of Paper 1 and the relevant business-related paper.

Signing Mou and launching an investigation

Step 2: Obtaining the appointment

It depends on the situation

Officially appointed by the insurer/agent/brokerage firm

Complete the investigation and sign the Spa

Step 3: Submit application online

1 day

Submitted through the Insurance Intermediaries Connect (IIC) electronic system

Regulatory applications and approvals

Step 4: IA Audit

5-20 working days

IA conducts appropriate candidate evaluation and document review.

Complete delivery

Step 5: Obtaining a license

Electronic license issued after review

Demand analysis and consulting

Step 1: Company Registration

1-2 weeks

Registering a company in Hong Kong (if not yet registered)

Signing Mou and launching an investigation

Step 2: Obtain appointment from the insurer

It depends on the situation

Sign agency agreements with at least one recognized insurer

Complete the investigation and sign the Spa

Step 3: Appoint a person in charge

4 weeks

Nominate at least one Royal (RO) and obtain IA approval (4 weeks)

Regulatory applications and approvals

Step 4: Establish a compliance framework

2-4 weeks To be confirmed

Establish AML policies, internal control systems, and grievance handling procedures.

Complete delivery

Step 5: Submit Application

1 day

Submit complete application materials through the IIC system

Obtain regulatory approval and pay the final payment

Step 6: IA Audit

12 weeks

IA conducts a comprehensive audit

Complete delivery and subsequent integration

Step 7: Obtaining a license

After review, a license was issued (valid for 3 years).

Demand analysis and consulting

Step 1: Company Registration

1-2 weeks

Registered company in Hong Kong + Paid-in capital ≥ HK$50

Signing Mou and launching an investigation

Step 2: Financial Preparation

2-4 weeks

Open a client account, purchase PII insurance, and ensure net assets ≥ HK$50

Complete the investigation and sign the Spa

Step 3: Appoint a person in charge

4 weeks

Nominate at least one Royal and obtain IA approval

Regulatory applications and approvals

Step 4: Establish a compliance framework

4-8 weeks To be confirmed

AML policy, internal controls, grievance handling, conflict of interest management

Complete delivery

Step 5: Submit Application

1 day

Submit complete application materials through the IIC system

Obtain regulatory approval and pay the final payment

Step 6: IA Audit

12 weeks

IA conducts a comprehensive audit (including verification of financial requirements).

Complete delivery and subsequent integration

Step 7: Obtaining a license

After review, a license was issued (valid for 3 years).

All license applications must be submitted online through the Insurance Intermediaries Connect (IIC) electronic system of the Insurance Authority (IA). The IA does not accept paper applications. Applicants must first register an account in the IIC system.

Insurance broker license fee details

IA will begin charging license fees starting September 23, 2024 — Full fee schedule and cross-license comparison.

Business categories New application (3 year) New application (2 year) New application (1 year) Renewal (3 years) Renewal (2 years)
General InsuranceGeneral Insurance HK$810 HK$600 HK$310 HK$810 HK$600
Long-term (excluding investment-linked contracts) HK$810 HK$600 HK$310 HK$810 HK$600
Long-term (including investment-linked) HK$1,090 HK$800 HK$420 HK$1,090 HK$800
General + Long-term (excluding investment-linked contracts) HK$1,620 HK$1,200 HK$620 HK$1,620 HK$1,200
General + Long-term (including investment-linked) HK$1,900 HK$1,400 HK$730 HK$1,900 HK$1,400
Limited scope of travel insuranceLimited-scope Travel Insurance HK$400 HK$290 HK$150 HK$400 HK$290

New application fee (3-year term)

Business categories New application fee
General InsuranceGeneral Insurance HK$7,200
Long-term (excluding investment-linked contracts) HK$7,200
Long-term (including investment-linked) HK$12,600
General + Long-term (excluding investment-linked contracts) HK$14,400
General + Long-term (including investment-linked) HK$19,800
Limited scope of travel insuranceLimited-scope Travel Insurance HK$4,000

Renewal fees (based on the number of sales representatives)

Number of people Renewal Fees
<100 people HK$2,250
100-1,000 people HK$4,500
>1,000 people HK$22,500

New application fee (3-year term)

Business categories New application fee
General InsuranceGeneral Insurance HK$14,400
Long-term (excluding investment-linked contracts) HK$14,400
Long-term (including investment-linked) HK$25,200
General + Long-term (excluding investment-linked contracts) HK$28,800
General + Long-term (including investment-linked) HK$39,600

Renewal fees (based on the number of sales representatives)

Number of people Renewal Fees
<100 people HK$4,500
100-1,000 people HK$9,000
>1,000 people HK$45,000
Expense items Amount of money
Application by the person in charge HK$1,800/time
Appointment notification fee HK$100/time
Article 79 exemption application HK$20,000
Licence type regulatory agency New application fee Valid period Annualized cost
Insurance brokerage firms (including investment-linked companies) IA HK$39,600 3 ~HK$13,200/year
Insurance agencies (including investment-linked insurance) IA HK$19,800 3 ~HK$6,600/year
Individual agents (including investment-linked securities) IA HK$1,900 3 ~HK$633/year

The IA waived license fees during the 2019-2024 transitional period. Formal fee charging started on 23 September 2024. The IA may waive part of the fee at its discretion. When an individual license is converted from one license type to another, a partial fee offset may be available.The IA waived licence fees during the 2019-2024 transitional period. Formal fee charging started on 23 September 2024. The IA may waive part of the fee at its discretion. When an individual licence is converted from one licence type to another, a partial fee offset may be available.

Confirmed

Based on the original text of Cap. 41 and the content explicitly stated in the IA's official guidelines/circuits.

Continuing compliance obligations

CPD, AML/CFT, Financial Reporting, Code of Conduct—Comprehensive Compliance Requirements After Licensing

Claim Specific standards status
Evaluation period August 1st to July 31st of the following year
Minimum CPD hours 15 hours/year
Ethics/Regulations Course Of which ≥3 hours must be related to conduct or regulations.
Additional requirements for RO Starting August 1, 2025, ROs must complete an additional 2 hours of management responsibility CPD. New regulations take effect
Travel insurance agentTravel insurance agents Only 3 hours/year required, no mandatory ethics courses.
e-learning No time limit
Excess carry-forward Cannot be carried forward to the next assessment period
Report deadline Within two months after the end of the assessment period (before September 30th)
record keeping CPD records must be retained for at least 3 years.

8 types of eligible CPD activities

CPD type Explain
Reviewed CPD activities (Type 1) For detailed requirements and accreditation criteria for reviewed CPD activities (Type 1), please refer to the official IA CPD guidelines.
Degree programs (Type 2) For detailed requirements and accreditation standards for the degree program (Type 2), please refer to the official IA CPD guidelines.
Qualifications Framework Accreditation Insurance Course (Type 3) For detailed requirements and accreditation standards for the Qualifications Framework Accredited Insurance Course (Type 3), please refer to the IA's official CPD guidelines.
Other Qualifications Framework Recognition Courses (Type 4) For detailed requirements and accreditation standards for other Qualifications Framework (Type 4) accreditation courses, please refer to the IA's official CPD guidelines.
Specified Qualification Learning (Type 5) For detailed requirements and accreditation standards for the specified qualification learning (Type 5), please refer to the official IA CPD guidelines.
Specified CPD eligibility requirements (Type 6) For detailed CPD qualification requirements (Type 6) and accreditation standards, please refer to the official IA CPD guidelines.
Events organized by IA/regulatory/law enforcement agencies (Type 7) For detailed requirements and accreditation standards for events hosted by the IA/regulatory/law enforcement agencies (Type 7), please refer to the official IA CPD guidelines.
Recognize CPD activities of professional organizations (Type 8) For detailed requirements and accreditation standards for CPD activities of accredited professional bodies (Type 8), please refer to the official IA CPD guidelines.
obligation Explain
Customer due diligence (CDD) Authenticate identity before establishing a business relationship.
Continuous monitoring Regularly review clients' risk profiles and trading patterns.
Suspicious transaction report Report suspicious transactions to the Joint Financial Intelligence Unit (JFIU).
PEP identification Determine if the client is a politically sensitive person.
record keeping At least 5 year
staff training Regular AML/CFT training
Compliance Officer Appoint a compliance officer to oversee AML/CFT compliance
obligation Explain
Maintain paid-in capital ≥HK$500,000 (ongoing)
Maintain net assets ≥HK$500,000 (ongoing)
PII Insurance Renewal Ensure PII insurance remains in effect, with compensation limits ≥ 2 times annual commission income.
Customer account management Customer premiums must be deposited into a separate customer account and must not be mixed with company funds.
Audited financial statements It must be submitted within 6 months after the end of each fiscal year.
Financial statement disclosure Commission income, customer account balance, and premiums payable must be disclosed.
obligation Explain
Best Interest Principle Brokers must act in the best interests of their clients.
Conflict of interest management Conflicts of interest must be identified, managed, and disclosed.
Commission disclosure Commission arrangements must be disclosed to clients.
Complaint Handling An effective complaint handling procedure must be established.
Information confidentiality Customer personal information must be protected.
Advertising compliance Marketing materials must be accurate and not misleading.
Types of violations Punishment
Operating without a license A fine of HK$100,000 plus two years' imprisonment
AML violation (legal entity) The maximum fine is HK$1,000 million.
AML violation (individual) The maximum fine is HK$100 million.
No audit report submitted Criminal conviction (first case: fine of HK$26,060)
Disciplinary action Reprimand, fine, suspension of license, revocation of license

Latest law enforcement cases

Three brokerage firms violated AML regulations.

Date: March 2026
PunishmentFines totaling HK$429,000 + reprimand
Violations: Failure to perform CDD, failure to identify PEP, and failure to save records.

Taihe Life Insurance

Date: March 2025
PunishmentA fine of HK$1,000 million
Violation: Unauthorized related-party transactions

Aurex Insurance Brokers

Date: March 2025
PunishmentA fine of HK$26,060 (first conviction)
Violation: Failure to submit audit reports

Prince Group Affiliated Companies

Date: March 2025
PunishmentProhibited from engaging in regulated activities
Violation: Affiliation with Prince Group

ICAC puppet agent case

Dates: February - November 2025
Punishment: Imprisonment for 11-46 months
Violation: HK$5,200 million fraudulent insurance policy scam

Major Supervision Updates in 2025-2026

A period of intensive regulatory reforms—from commission reforms to comprehensive changes in AML enforcement.
June 2025 New regulations take effect

IUL classifies it as a Class C product.

Joint circular from the IA and HKMA: Investment-linked life insurance (IUL) is classified as a Class C complex product and is only available to professional investors.
Influence:Brokerage firms must update their product categorization and sales processes.
August 1, 2025 New regulations take effect

New requirements for CPD (Chief Product Manager)

The person in charge must complete 2 hours of management responsibility CPD, which will be counted in the "Culture/Regulations" category and the total 15 hours.
Influence:All ROs must ensure they complete their 2-hour management responsibility CPD.
October 1, 2025 New regulations take effect

Referral fee cap

Referral fees must not exceed 50% of the total commission.
Influence:Intermediaries who influence the referral model
January 1, 2026 New regulations take effect

Policy commission sharing system

Commissions in the first year shall not exceed 70% of the total commissions, with the remainder to be amortized into subsequent years.
Influence:Significant impact on intermediaries' cash flow and business model
January 1, 2026 New regulations take effect

Background check program launched

IA launches background check program for insurance intermediaries to enhance the assessment of suitable candidates.
Influence:Both new applicants and existing licensees are affected.
Shield 1
June 2025 New regulations take effect

VA Insurance Product Regulation

The Insurance Authority (IA) has released guidelines for insurance products related to virtual assets, clarifying the regulatory framework.
Influence:Intermediaries involved in VA products must comply with additional requirements.
June 2025 Confirmed

JD.com obtains insurance brokerage license

JD.com's acquisition of an insurance brokerage license by the Insurance Institute (IA) marks an accelerated entry of InsurTech into the Hong Kong market.
Influence:Traditional intermediaries face digital competition
June 2026 Confirmed

AML enforcement efforts strengthened

The Insurance Authority (IA) fined three brokerage firms a total of HK$429,000 for violations of AML/CFT regulations.
Influence:All intermediaries must strengthen AML compliance.
09 Warning
2025-2026 will be a period of intensive reforms for the supervision of insurance intermediaries in Hong Kong.
All licensed intermediaries are advised to pay close attention to updates to IA circulars and guidelines, and adjust their business processes and compliance structures accordingly. Aiying Compliance Technology provides ongoing regulatory updates and compliance consulting services.

Cross-license relationships and multiple regulations

Other licensing requirements and regulatory bodies that insurance intermediaries may be involved with

Cross-license trigger scenarios

Insurance Broker License SFC Type 1 (Securities Trading) License
If a brokerage firm sells investment-linked insurance products (ILAS), it may be required to hold an SFC license.
Triggering scenario: Selling investment-linked insurance products containing securities components.
Insurance Broker License MSO License (Money Service Operator)
If currency exchange or remittance services are involved (such as cross-border insurance premium payments), an MSO license must be applied for separately.
Triggering scenario: Processing cross-border insurance premium payments involving currency exchange.
Insurance Broker License TCSP license (trust or corporate service provider)
If services such as company secretarial work and registered office services are also provided, a TCSP license is required.
Triggering Scenario: Providing company establishment and management services to clients.
Insurance Broker License VA Dealing / VATP License
If the transaction involves virtual asset-related insurance products or VA transactions, an SFC-related license is required.
Triggering scenario: Selling VA-related insurance products or providing VA transaction services.
New regulations take effect
Insurance Broker License MPF Intermediary Registration
If you are also selling MPF products, you must register as an MPF ​​intermediary with the MPF Authority.
Triggering scenario: Selling Mandatory Provident Fund (MPF) related products

Regulatory landscape

regulatory agency Scope of supervision Major Regulations
Insurance Authority (IA) Insurance intermediaries (brokers, agents, business representatives) Insurance Ordinance, Cap. 41
Securities and Futures Commission (SFC) Securities trading, futures trading, VA trading Securities and Futures Ordinance, Cap. 571
Hong Kong Monetary Authority (HKMA) Banking and insurance channels Banking Ordinance, Cap. 155
Mandatory Provident Fund Schemes Authority (MPFA) MPF intermediary Mandatory Provident Fund Schemes Ordinance, Cap. 485
Customs and Excise Department (C&ED) Money service operators Anti-Money Laundering Ordinance, Cap. 615
Companies Registry (CR) Trust or corporate service providers Anti-Money Laundering Ordinance, Cap. 615
Hong Kong's financial supervision adopts a "functional supervision" model, meaning that the same institution may be supervised by multiple regulatory authorities for different business activities. It is recommended to conduct a comprehensive assessment of licensing needs during the business planning stage to avoid the risks of operating without a license.

Frequently Asked Questions (FAQ)

Frequently Asked Questions about Hong Kong Insurance Intermediary Licenses
Insurance brokers represent the interests of their clients, can compare products from multiple insurers, and are independent of the insurers; insurance agents represent the interests of the insurers and only sell products from the insurers they represent. Brokerage firms must meet higher financial requirements (paid-in capital ≥ HK$50, PII insurance, etc.).
The standard processing time for an Information Authority (IA) is 12 weeks (approximately 3 months), but the actual time depends on the completeness of the application materials and the IA's review progress. Including preliminary preparations (company registration, RO approval, and compliance structure setup), the entire process typically takes 4-6 months. To be confirmed
The passing score for each volume of the IIQE is 70%. The exam is administered by the VTC and consists of multiple-choice questions. Specific pass rates are not publicly disclosed by the IA, but industry estimates suggest a pass rate of approximately 60-70% for Volume 1 and slightly lower for the professional volumes. Those holding relevant professional qualifications may apply for exemptions. To be confirmed
The minimum compensation limit is twice the annual insurance brokerage revenue (note that this is gross revenue, not net revenue). The deductible shall not exceed 50% of the company's net assets. PII insurance must remain in effect and cannot be interrupted.
Yes, but the following conditions must be met: (1) having legal residency/work rights in Hong Kong; (2) passing the IIQE exam; (3) being appointed by an insurer/agent/brokerage firm; and (4) passing the IA suitability assessment. The company must also hold an institutional license and be registered in Hong Kong.
The responsible person is an IA-approved individual responsible for overseeing and managing the regulated activities of the organization/company. Each licensed insurance agency and brokerage firm must appoint at least one RO, who must be a director or partner of the organization/company. RO approval takes approximately 4 weeks and costs HK$1,800 per instance.
Starting January 1, 2026, commissions for participating insurance policies will not exceed 70% of total commissions in the first year, with the remainder spread over subsequent years. This will significantly impact intermediaries' cash flow and business models, particularly those reliant on high first-year commissions. It is recommended to adjust financial planning in advance. New regulations take effect
If the referral activity involves regulated activities (such as promoting specific insurance products), the referrer must be licensed. From October 1, 2025, referral fees cannot exceed 50% of total commissions. The IA is intensifying its crackdown on unlicensed referral activities. New regulations take effect
Failure to meet the CPD requirements may lead the IA to refuse licence renewal, impose additional conditions, or take disciplinary action. From 1 August 2025, responsible officers must complete 2 hours of CPD on management responsibilities, counted within the ethics/regulatory category and the 15-hour total. CPD hours cannot be carried forward to the next assessment period.
Aiying Compliance Technology provides end-to-end license application support, including: license type assessment, IIQE exam preparation guidance, application material preparation, compliance framework setup, AML policy development, RO application assistance, and ongoing compliance management. Our team is familiar with IA review standards and processes, helping clients achieve efficient approval.

About Aiying

Aiying (License.aiying.cc) specializes in global traditional finance and Web3-related license application and acquisition consulting services. With teams primarily located in Hong Kong, the UAE, and Europe, and strong relationships with local regulators, Aiying has successfully secured applications and smooth operations for leading and mid-tier crypto and traditional institutions. Team members are qualified in Hong Kong, Europe (Ireland), the UK, the UAE, and other jurisdictions, with a global network ensuring 24/7 professional support. Headquartered in Asia, the team brings together experts in operations, marketing, law, regulatory compliance, and accounting, adhering to clients' business objectives to provide comprehensive and in-depth strategies and solutions.
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This mechanism allows us to ensure that the materials submitted to regulators are highly professional, complete, and impeccable, thereby minimizing regulatory inquiry rounds, significantly shortening approval times, and reducing the license rejection rate by 67%.