1. What is an insurance broker? Who is suitable to set up an insurance brokerage company?
Legal definition of insurance broker
Refers to an agent who is a policy holder or potential holder，Operating in Hong Kong、Negotiating or arranging insurance contracts，or a person carrying on a business of advising on insurance matters。Customer interests must come first。
Independent sales team (IFA)
Existing IFA or insurance sales team，Hope to be independent，Or want to transform from a single insurance agency to a brokerage company that can provide diversified products and neutral advice。
overseas financial institutions
Overseas financial institutions wishing to tap into Hong Kong’s mature insurance and capital markets、Mainland wealth management company or cross-border insurance intermediary。
family office (Family Office)
A family office that provides comprehensive asset allocation and inheritance planning for high-net-worth clients，Providing direct insurance brokerage and trust ancillary services by holding a license。
2. Minimum requirements under the Insurance Companies Ordinance
(A) Qualifications and experience：Responsible person(RO)Must be 21 years or older，Be a permanent resident of Hong Kong(Or hold a valid work visa)；At least a bachelor's degree or equivalent；Hold recognized insurance qualifications，And have at least 5 years of experience in the insurance industry (including at least 2 years of management experience)。
(B) Capital and net assets：Corporate insurance brokers are required to keep a minimum of Hong Kong dollars at all times 500,000 The minimum net asset value and paid-up capital of。When determining net worth，Excludes all intangible assets，and must be calculated in accordance with Hong Kong generally accepted accounting principles。
(C) professional indemnity insurance (PII)：A professional indemnity policy must be kept，The minimum indemnity limit is：2 times total brokerage revenue over the past 12 months (or projected 12 months)，or Hong Kong dollars 3,000,000 Yuan，Whichever is the larger of the two (the maximum amount is NT$75 million)。
(D) Separate client account：Client funds must be deposited into a separate client bank account (containing”Client Account”typeface)，Client funds may not be used for any purpose other than the purpose for which the client is concerned。
(E) Keeping Proper Accounts and Proper Personnel：All transaction and asset and liability records must be retained for no less than 7 years。Brokers must meet the "fit and proper" requirements，Conduct business with the highest integrity，No conflict of interest，Never disclose client confidential information。
3. Qualification requirements for core personnel (shareholders/directors/responsible personnel)
shareholder (Controller)：Directly/indirectly holding 15% or more of the equity as a controller。Fill out S5 form personally，Company fills out S6 form。No serious criminal or financial offenses required、No major disciplinary action、Not bankrupt，And can provide proof of reasonable source of funds (tax bill/monthly statement)。
director (Directors)：Not every director may have an insurance background，But have the ability to oversee corporate risk management、Compliance and Finance。No fraud/money laundering record required、No regulatory agency sanctions、non-bankrupt person。
Responsible person (RO)：The main person in charge in the eyes of IA，Ensure the company adheres to guidelines and monitor day-to-day compliance。RO's past work experience must strictly match the business scope applied for by the company (general/long-term/connected)。
4. A list of hard documents before formally submitting the application
official form：A4 "Insurance Brokerage Company License Application"、A3 "Application for Accreditation of Proposed Appointment of RO"、A1 "Personal Intermediary License"(If applicable)、S5/S6 "Director/Controller Information Declaration"。
RO detailed resume：The name of the employer must be clearly stated、Nature of business、Positions and responsibilities (focus on sales supervision/compliance/internal control)、Management experience (number of people and structure)，Attach IIQE passing scores and academic certificates。
Three core architecture diagrams：1) Shareholding structure chart (penetrating to the ultimate beneficial owner UBO)；2) Group structure chart (showing listed or overseas regulated entities)；3) Organizational Chart (Board of Directors、Division of work between RO and various business/compliance/AML/finance departments)。
Financial and bank documents：Latest financial statements(Established >12 months)or management accounts；Company operating bank account monthly statement；customer account(Client Account)A copy of the s.71 written notice；PII Professional Indemnity Insurance Quote。
Recommendation letter from insurance company：Each business area (general/long-term/connected)，At least required 3 Letters of recommendation for cooperation intentions from different insurance companies (can be combined into one letter to describe multiple businesses)。
5. business plan (Business Plan) of 4 big core direction
1. Insurance products to be sold
Clarify the scope of application：General insurance (car insurance、travel、employees compensation, etc.)；Long-term insurance (life、medical、critical illness)；Linked Long-term Insurance (ILAS/Investment Linked Life Insurance)。
2. Customer service scope
Clarify business segments：Including using KYC and FNA to assess customer risk；Provide solution comparison；Process insurance documents；and subsequent policy review、Insurance renewal management and claims assistance。
3. Target markets and customers
Define customer types：Such as local residents of Hong Kong、non-resident、professionals、high net worth individuals、Small and medium enterprises(SME)Group medical clients or family offices, etc.。
4. Core business sources
Explain customer acquisition channels：Such as through referrals from existing customers、Enterprise/Chamber of Commerce Cooperation Lectures、Provide consultation on employee benefit plans，or attract inquiries through online content marketing and comparison tools。
6. Internal Control Policies and Procedures (Three Core Compliance Manuals)
1. Operations Manual (Operations Manual)
Covers the entire process of frontline operations：From contacting customers → KYC/FNA → Compare options → Suggestions → Apply for insurance → Issue orders → Claim settlement。Customer agreements must be used in a standardized manner、Forms such as RPQ and IFS；Clarify the client fund handling and independent account reconciliation process；Standardize insurance policies and AML information to be kept for at least 7 years。
2. Compliance Manual (Compliance Manual)
Establish governance structure and RO reporting line；Requires onboarding due diligence and annual self-declaration(FIT and Proper)；Implement at least 15 hours of CPD training every year(Includes 3 hours of ethics)；Specify the compliance monitoring and spot check process、Guidance on transfer of insurance、Cooling off period enforcement、Complaint incident management and anti-corruption gift-giving policy。
3. Anti-Money Laundering Handbook (AML / CFT Manual)
risk-based(RBA)frame，to customers、product(High Long Term Savings/ILAS)and channel classification。required due diligence(CDD)and strengthen due diligence(EDD)Trigger condition；Develop sanctions list name screening(Name screening)frequency；Clarify the frontline red flags of suspicious transactions and the reporting process to JFIU。
7. Analysis of the entire licensing process (expected 4 - 6 months)
step 1：Early planning and structure establishment
Determine the company's shareholding structure、Application business scope (can apply for 3 categories at the same time)，Provide sufficient paid-in capital and net assets，Looking for RO candidates with relevant experience。
step 2：Writing plans and internal control manuals
Write a business plan；Obtain at least 3 recommendation letters from insurance companies in each business scope；Tailor-made operations manual、Compliance Manual and AML Anti-Money Laundering Manual。
step 3：Prepare financial and account opening information
Prepare recent financial statements or management accounts；Get a PII Indemnity Insurance Quote；Open a bank "operating account" and a "client capital account" containing the words "Client Account"。
step 4：to the Insurance Regulatory Bureau(IA)Submit paper application
Complete A4、A3、S5 and other forms and more than 20 attachments，Submit IA。After passing the preliminary review by IA，Issue payment notice，After payment, you will officially enter the approval process.。
step 5：Respond to multiple rounds of written inquiries from the Insurance Regulatory Authority
The IA will request a written explanation from the company within a deadline (approximately 7-14 days)：RO’s time commitment and supervisory capabilities、Source of funds、Reasonableness of revenue forecasts、Internal control forms(KYC/FNA)actual implementation details, etc.。
step 6：Approval in principle and formal licensing
After satisfactory defense，IA issues "in-principle approval"。Applicant submits official PII original policy copy、After the final bank statement and other pre-licensing condition documents，Officially issued a license。
8. 5 A fatal mistake that caused the application to be "stillborn"
Shareholder background blurred：actual controller(COUGH)The source of funds is unclear，Failed to provide satisfactory tax returns or bank statements，Or involving multiple layers of complex overseas companies。
Difficulties in opening an account and stuck funds：The company has been unable to open a bank "operating account" or "customer account"；“Paid-in share capital” barely reaches HK$500,000，Initial expenses fell below regulatory red lines as soon as they were released。
RO experience mismatch or only nominal：RO’s past experience does not match the applied business (such as connected long-term products)，Or it may be discovered by IA inquiry that it is just a "listing" without actual management rights.。
Internal Control Manual "Copy the Template"：The three major manuals seem to be thick，But it is not consistent with the actual business plan；KYC/FNA and other forms are not customized according to the latest IA guidelines.。
Can't get enough letters of recommendation：Failure to reach a consensus on cooperation with the insurance company before application，Unable to collect every business category 3 The above formal letter of recommendation for cooperation。
9. Insurance Regulatory Bureau (IA) Official Fee Schedule for License Application (3term license)
| Business scope portfolio | Official application fee (HK$) |
|---|---|
| General business | $14,400 |
| Long-term business (excluding connections) | $14,400 |
| Long-term business (including connected) | $25,200 |
| generally + Long-term business (excluding connections) | $28,800 |
| generally + Long-term business (including connected) | $39,600 |
| person in charge (RO) Approval application fee | $1,800 / per person |
Note：The above are only the official fees collected by the Insurance Regulatory Bureau，Does not include professional consulting fees、PII premiums and company daily operating expenses。
10. Frequently Asked Questions about Hong Kong Insurance Broker License (FAQ)
An insurance broker is an intermediary who represents clients (policyholders) to find suitable insurance products.。As long as it involves recommending/comparing insurance products in Hong Kong、arrange insurance、Provide advice or handle claims，You must apply for an insurance brokerage license from the Insurance Regulatory Bureau。
Regulations require that the minimum paid-up share capital and net assets of a corporate insurance broker shall not be less than HK$500,000 at any time。But in order to meet daily expenses and prevent falling below the regulatory red line as soon as it opens,，We strongly recommend that the paid-in capital be at least HK$800,000。
RO must be a permanent resident of Hong Kong or hold a legal work visa，Bachelor's degree，Pass the relevant IIQE exam，And have at least 5 years of insurance experience (including no less than 2 years of management experience)。The most important thing is，The RO's experience must be highly consistent with the business category the company is applying for.。
Each business area requires at least 3 Letters of recommendation from different insurance companies。If you apply for general and long-term business，then need 3 A general business recommendation letter and 3 A long-term business recommendation letter (if the same insurance company operates both，Two businesses can be stated in the same letter)。
If you do not collect premiums on behalf of customers，Theoretically no need。However, most brokerage companies will collect premiums or refund them for business convenience.。Once collection is involved，You must open a separate account clearly marked with the words "Client Account" at the bank，Mixing with company working capital is strictly prohibited。
PII stands for professional indemnity insurance，Used to compensate for losses caused to clients due to brokerage negligence。Simply submit a quotation during the application stage；But after receiving "in-principle approval"，You must formally purchase and submit the original policy (insured amount not less than HK$3 million or twice the expected income) in order to exchange for a formal license。
Refers to the operations manual (standardized sales process、KYC、FNA）、Compliance Manual (Government Complaints、Guidance on transfer of insurance、CPD training)、and the Anti-Money Laundering Manual (AML Risk Assessment、Customer due diligence and suspicious transaction reporting)。This is the top priority of the IA’s review。
FNA stands for "Financial Needs Analysis"，RPQ stands for "Risk Tolerance Questionnaire"。Hong Kong Insurance Regulatory Authority cracks down on mis-selling，Brokerage firms are required to ask customers to fill in these forms during their business processes，Ensure recommended products are consistent with customers’ true financial situation and risk tolerance。
Prepare documents from the beginning、It takes about 1-2 months from registering a company to submitting the application.；After submission, it will take about 3-4 months for review and multiple rounds of questioning by the Insurance Regulatory Bureau.；The overall expected time is approximately 4 to 6 months。
will be subject to strict scrutiny。If the nominated RO holds core positions in two companies at the same time，Must provide relevant shareholder certificates to regulators、Reasonable explanation、Resolutions of the two companies’ boards of directors accepting concurrent posts，and prove that they have sufficient time and energy to perform their duties。
Can。Controllers (holding more than 15% of shares) are not limited to nationality，However, you must fill in the S5 form and accept the "fit and proper person" review.，Proof of no criminal/violation record，And provide tax receipts or bank statements to prove that the source of investment funds is legal and reasonable.。
On behalf of the Insurance Regulatory Commission, it is satisfied with your application documents and defense.，Agree to deal，However, there are "pre-licensing conditions" attached (such as the official opening of a customer account).、Buy PII insurance)。Once you have completed these final actions and submitted your credentials，Formal license issued immediately。
11. Our one-stop licensing compliance service
Full license agency
Assistance in registering a Hong Kong company、Recruitment and Assessment Manager(RO)、Drafting business plans and in-depth customization of three major internal control manuals，Submit a complete set of paper applications to the Insurance Regulatory Bureau on your behalf。
Overcome account opening difficulties
With profound industry resources，Assist insurance brokerage companies to sort out account opening logic，Smoothly open a bank operating account and an extremely strict independent "customer capital account"。
Regulatory defense and follow-up
Professional compliance experts will handle the matter and accurately respond to the Insurance Regulatory Bureau.(IA)A multi-page written inquiry issued，Coaching RO interviews，Until in-principle approval is obtained。
