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 officers: Requires approval from the Insurance Authority (IA), 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) Share capital and net assets: According to sections 3 and 4 of Chapter 41L, The fully paid-up share capital and net assets shall at any time not be less thanHKD 500,000. Net assets must be calculated in accordance with applicable accounting standards, with intangible assets and related lease liabilities treated under section 4(2); Ended legacy company transition amounts do not apply to current requirements.
(C) professional indemnity insurance: Regulation 5 of Chapter 41L, Limits of indemnity per claim and per 12-month policy period, Generally, it is twice the insurance brokerage income for the previous 12 consecutive months (the highest amount of income timesHKD 75,000,000)andHKD 3,000,000the higher of; The limit for the first 12 months of operation shall not be less thanHKD 3,000,000, and must have at least one automatic reinstatement clause. The deductible is subject to the 50% limits in sections 5(5) and 5(6).
(D) client money: If you receive or hold client money, Section 6 of Chapter 41L requires the maintenance of at least one complying customer account, The account name must contain "client", Provide Section 71 written notice to the bank where the account is held and keep records. Customer funds must be restricted for use in receipts and payments, And reconcile the accounts at least once every calendar month.
(E) accounts, Records and fit and proper persons: According to the Insurance Ordinance, Cap. 41L, Code of Conduct and applicable AML/CFT and Privacy Rules Maintaining accounts and business records; Record-retention periods, disclosure exceptions, 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..
directors: 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 officers (RO): Requires approval from the Insurance Authority (IA), 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 Authority (IA) 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 Authority (IA) on the filing date, responsible officers, 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, Policy replacement, cooling-off periods, complaints, 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, products(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 Authority (IA)
Form valid at time of submission, List and Submission Channel Submitting Company, responsible officers, technical representative, directors, Controller and business information, And pay the applicable fees or supplementary documents as notified by the Insurance Authority (IA).
step 5: Respond to Insurance Authority (IA) inquiries
The Insurance Authority (IA) 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 Authority (IA) 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 automatic licence approval.
8. 5 A fatal mistake that caused the application to be "stillborn"
Shareholder background blurred: ultimate beneficial owner (UBO) / actual controllerThe 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. Application fees and payment arrangements
Before applying, you should follow the type and validity period of the license you intend to apply for., Check company licenses separately, Charges and payment arrangements for responsible personnel and other applicable items. Application fee, Annual Fees and Conditions Applicable to Any Waiver, Please refer to the current official charging information and official notice..
Please checkInsurance Authority license application information, and check the forms used before submitting the application, Document list and payment method.
10. Frequently Asked Questions about Hong Kong Insurance Broker License (FAQ)
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 Authority (IA) 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 Authority (IA) 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
| Illustrative scene | Information that needs to be sorted out first | Issues that should be checked item by item |
|---|---|---|
| Plan to establish an insurance brokerage company | Customers to be served, Insurance business scope, Business process and company structure description. | Whether the proposed activities require corresponding qualifications; Is the application scope consistent with the actual business?. |
| Arrange personnel and company resources | Resumes of responsible personnel and business personnel, Responsibilities Arrangement, and financial resources and professional indemnity insurance information.. | Personnel qualifications, Whether the responsibilities match the business to be carried out; Whether financial and insurance arrangements meet applicable requirements. |
| Establish daily internal system | Customer data management, complaint handling, Conflicts of interest and applicable draft anti-money laundering regime. | Is the system consistent with the actual work process?; How to save records, Fulfill responsibilities and continuously update. |
Can read firstHong Kong Insurance Broker License Application Information Instructions. Involving qualifications, Financial and insurance conditions, Current regulations of the Insurance Authority (IA) should be checked separately; The result of the application is determined independently by the competent authority.
13. Hong Kong Insurance Brokerage License IA-Application related information sharing
1, Insurance Authority (IA): Insurance Brokerage Company License Application Checklist (2026 Chinese)
2, Insurance Authority (IA): Insurance intermediary license application
3, Insurance Authority (IA): Regulatory information on licensed insurance brokerage companies
4, Insurance Authority (IA): 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 Authority (IA): Insurance intermediaries register
share capital, Net worth and professional indemnity insurance conditions in accordance with the applicable version of Chapter 41L; personnel, The form and fee must be checked against the current official information before submission..