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，By holding a license to provide direct insurance brokerage andTrust supporting services。
2. Key continuing requirements under the Insurance Ordinance and existing rules
(A) Responsible person：Requires approval from the Insurance Regulatory Authority、fit and proper person，And have qualifications commensurate with the type of business applied for、experience、Authority and actual ability to perform duties。residence status、Educational qualifications、take an exam、Experience and exemptions should be checked on a case-by-case basis according to the candidate and submission guidelines，It should not be written as a uniform threshold for all cases。
(B) Equity and net asset value：Licensed insurance brokers must continue to comply with the Insurance (Financial and Other Requirements for Licensed Insurance Brokers) Rules (Chapter 41L) and the current requirements of the Insurance Authority。Amount、Calculation items and transitional arrangements must be reviewed against the current text upon submission and each reporting period。
(C) professional indemnity insurance：Eligible protection must be maintained in accordance with Chapter 41L and the prevailing rules of the Insurance Authority。minimum indemnity limit、revenue base、upper limit、Deductibles and policy terms should be calculated based on applicable period and actual brokerage income。
(D) Customer money：If you receive or hold client money，Funds must be deposited into appropriate client accounts and restricted for use in accordance with Chapter 41L；Account name、bank notification、Reconciliation and authorization arrangements are implemented in accordance with current rules and bank requirements。
(E) accounts、Records and fit and proper persons：According to the Insurance Ordinance、Chapter 41L、Code of Conduct and applicable AML/CFT and Privacy Rules Maintaining accounts and business records；shelf life、Exception to show off、Conflicts of interest and confidentiality obligations must be determined based on the type of record and legal basis。
3. Qualification requirements for core personnel (shareholders/directors/responsible personnel)
Shareholders and controllers：control relationship、Shareholding and voting rights must be judged according to the definitions in the Insurance Ordinance。Relevant individuals or corporations should use the form valid at the time of submission，Disclosure of ownership、Integrity、financial condition、Information such as disciplinary records and funding sources；You cannot draw conclusions based solely on a single shareholding ratio or document list.。
director：Subject to fitness and governance assessments based on their role，and be able to oversee the business、risk、Compliance and Finance。criminal、discipline、Bankruptcy、Integrity、Competencies and conflicts of interest will be considered based on complete facts.。
Responsible person (RO)：Requires approval from the Insurance Regulatory Authority，and have sufficient authority and supervisory capabilities over brokerage business and internal control.。its qualifications、Experience and type of authorized practice must be commensurate with actual duties；Compliance with the requirements will be assessed by the Insurance Regulatory Authority on the basis of evidence.。
4. A list of hard documents before formally submitting the application
official form：Use the insurance brokerage company published by the Insurance Regulatory Authority on the filing date、Responsible person、technical representative、Directors and Controllers Forms and Checklists；Form number、Versions and electronic or paper submission methods must be submitted for review shortly.。
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。
Insurance company cooperation information：Prepare the insurer's intention based on the 2026 insurance brokerage company application list and proposed business types、Business sources or other supporting documents；required quantity、The format and whether it can be merged shall be subject to the current list and case notification.。
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)
Contact customers with actual business descriptions、due diligence、Need analysis、product comparison、suggestion、Insure、Policy services and claims assistance；Customer Agreement、Questionnaire、Documentation、Customer payments and record keeping are subject to product、Customer and current rule configuration。
2. Compliance Manual (Compliance Manual)
Describe the governance structure、Reporting route for the person in charge、Fit and proper check、Continuing professional training、sales monitoring、Reinsurance、cooling off period、complaint、Incident and conflict of interest management。CPD hours and designated topics are checked according to licensee type and current guidelines，Cannot be generalized to uniform hours for all employees。
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. Overview of licensing process (actual time will be determined by the Insurance Authority on a case-by-case basis)
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 business plans and internal control documents according to the business category to be applied for，And prepare insurance cooperation or other supporting information according to the application list when submitting。
step 3：Prepare financial and account opening information
Prepare financial statements or management accounts、Funding sources and professional indemnity insurance information；Bank account and customer payment arrangements by business、Current rules and banks’ independent due diligence implementation。
step 4：Submit an application to the Insurance Regulatory Authority
Form valid at time of submission、List and Submission Channel Submitting Company、Responsible person、technical representative、director、Controller and business information，And pay the applicable fees or supplementary documents as notified by the Insurance Regulatory Authority。
step 5：Respond to Insurance Regulatory Authority inquiries
The Insurance Regulatory Authority may take responsibility for the performance of duties by the responsible person、funds、predict、Internal monitoring and actual implementation Raising inquiries or requesting supplements。query round、Reply deadline、Interviews and other procedures are notified on a case-by-case basis。
step 6：Regulatory decisions and pre-licensing matters
The Insurance Regulatory Authority may approve、Additional conditions、Refuse or require that specified items be completed first。Professional indemnity insurance required、Account、Documents and effective arrangements are subject to official notification，Completing the supplement does not mean automatically issuing cards。
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。
Insufficient financial resources：share capital、net asset value、cash flow、Professional indemnity insurance and client payment arrangements are not continuously calculated in accordance with applicable rules；Bank accounts are still determined by the bank’s independent due diligence。
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.。
Support information is inconsistent with business plan：Failure to submit insurance cooperation or other supporting information according to the current list，Or information and application category、Conflicting revenue forecasts and operating arrangements。
9. Insurance Regulatory Authority license fee review tips
The business portfolio and responsible person amounts listed on the original page cannot be independently read back and confirmed from the Insurance Regulatory Authority website.，Temporarily removed，Avoid items that may expire、The amount waived or not applicable to the case is marked as the current official fee。
Please click before submittingInsurance Regulatory Authority license application page、Current charging information and formal payment notice，Check license type、Validity period、Application fee、annual fee、Responsible Personnel Fees and Any Waivers。
10. Frequently Asked Questions about Hong Kong Insurance Broker License (FAQ)
Insurance brokers typically operate on behalf of policyholders or potential policyholders、Negotiate or arrange insurance contracts，or provide advice on insurance matters。Whether the specific activity is a regulated activity and the license required，Should be in accordance with the Insurance Ordinance、Role、Judgment of location and actual process。
authorized share capital、net asset value、Professional indemnity insurance and working capital are different concepts。The minimum amount and calculation must be reviewed in accordance with Chapter 41L and the rules at the time of submission；Additional operating buffer depends on business plan，There is no statutory HKD 800,000 threshold that Hong Kong Express can recommend uniformly.。
The responsible officer must be approved by the Insurance Authority and be a fit and proper person、qualifications、experience、Authority and performance requirements。Residence、Educational qualifications、take an exam、experience、Management experience and exemptions are assessed on a case-by-case basis by candidate and business type，Cannot always be written as permanent resident、Undergraduate and fixed-year combination。
Prepare insurance cooperation or other supporting information based on the 2026 insurance brokerage company application list and proposed application categories。quantity、Issuing subject、The content and whether it can be merged shall be subject to the submission list and the Insurance Regulatory Authority’s case notification.。
Whether a client account is required depends on whether client money is received or held and the specific application of Chapter 41L。Compliance accounts must be used when client money is involved、Limit usage and perform reconciliation and authorization controls；The account name and notification documents are subject to current rules and bank requirements.。
Professional indemnity insurance is used to cover brokerage professional liability risks under the Rules。Quotations required during the application stage and before licensing、insurance policy、Limit of indemnity、Deductibles and Documentation Forms，Subject to Chapter 41L、Current list and confirmation from Insurance Regulatory Authority notification。
Internal control documents typically cover governance、Sales and Operations、complaint、training、Customer money、AML/CFT and record keeping。Specific document names and depth should be consistent with the business plan、product、Client and outsourcing arrangements consistent，and pressInsurance Regulatory Authority Brokerage Company Informationrenew。
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。
The Insurance Regulatory Authority has not committed to a unified review and approval cycle in the information on this page.。Prepare、Supplementary parts、People and control structure、Business complexity and regulatory inquiries will affect time，Should be planned on a case-by-case basis and allow time for replacement.。
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。
Non-Hong Kong persons are not automatically excluded，But the identity of the controller、sheet、fit and proper person、Source of funds、Delivery and actual management arrangements must be confirmed item by item in accordance with the Insurance Ordinance and the information submitted.，It cannot be summarized by just 15% or a single table。
If the Insurance Regulatory Authority notifies the applicant to complete specified matters first，The legal nature of the notification should be、Conditions and deadlines apply。Submit professional indemnity insurance、After account or other information，Still have to wait for the Insurance Regulatory Authority’s formal decision，It cannot be expressed as immediate dealing of cards。
11. Our one-stop licensing compliance service
Full license agency
Assist the company within the agreed scope、personnel、Preparation of business plans and internal monitoring materials，and submit it to the Insurance Regulatory Authority through the effective channels at the time of submission.；recruitment、Legal services and regulated activities are performed by appropriately qualified independent persons。
Overcome account opening difficulties
Can assist in organizing bank due diligence and account usage information；Whether to open an operating or customer account、The required time and conditions are determined independently by the bank，Account opening results cannot be guaranteed。
Regulatory defense and follow-up
Can assist in organizing Insurance Regulatory Authority inquiries and interview preparations；Statements of fact must be confirmed by the applicant and the responsible officer，Consultants cannot perform duties on their behalf，Nor can we promise in-principle approval or licensing.。
12. Hong Kong Insurance Broker License | Typical Application Preparation Scenarios
13. Hong Kong Insurance Brokerage License IA-Application related information sharing
2、Insurance Regulatory Authority：Insurance intermediary license application
3、Insurance Regulatory Authority：Regulatory information on licensed insurance brokerage companies
4、Insurance Regulatory Authority：Fit and proper guidance (GL23)
5、Insurance Ordinance (Chapter 41)
6、Insurance (Financial and Other Requirements for Licensed Insurance Brokers) Rules (Chapter 41L)
7、Insurance Regulatory Authority：Insurance intermediaries register
Verification instructions：The Insurance Regulatory Authority’s web pages and PDFs returned a 403 anti-crawling response during this round of inspections.，Not considered a broken link；Version must be rechecked after restoration of access、Fees and forms。
