Hong Kong Regulatory Insurance Update - Spring 2024

In this Spring 2024 edition of Regulatory Insurance Update, the Hong Kong Corporate and Commercial Team provides the latest updates relating to the law and regulations, developments, and news in the insurance industry in Hong Kong.

Hong Kong_Skyline At Sunrise

Updates on insurance law and regulation

1 February 2024

The IA has welcomed commencement of the consultation process and start of the legislative work by the Hong Kong Government on Article 23 of the Basic Law (which introduces new laws in Hong Kong to prohibit treason, sabotage, sedition, espionage and the theft of state secrets).[1]

Mr Stephen Yiu, the IA’s Chairman, commented that the legislative work would be an “important step in fulfilling our constitutional duty” and that it would help “create a safe and orderly business environment, strengthen investor confidence and reinforce Hong Kong’s position as an international financial centre and global risk management centre.”

The IA will communicate closely with the insurance sector to assist its understanding of the legislative proposals.

[1] The Article 23 legislation came into force on 23 March 2023.

Link to IA press release

Link to Insurance Asia article

Insurance industry news and developments 

21 February 2024

The IA has released its 2022-2023 annual report which is titled “Strive for Success in the New Chapter”. The IA’s aim is to consolidate Hong Kong’s position as a global risk management centre and sophisticated insurance hub. The report aligns with the Hong Kong Government’s Development Roadmap for the Insurance Sector in Hong Kong.

The report outlines the following key initiatives:

  • passing the Insurance (Amendment) Bill 2023 to implement a risk-based capital regime;
  • enhancing standards of conduct across the insurance sector;
  • elevating Hong Kong’s status as an attractive captive domicile and a vibrant hub for insurance-linked securities; and
  • launching public education campaigns to boost the public’s understanding of insurance products, as well as the industry at large. 

Hong Kong’s insurance sector is reported to have underwritten a total gross premium of HK$538 billion; ranking first in Asia for insurance density and second in Asia for insurance penetration.

In terms of complaint handling, the IA received 1,083 new cases and closed 1,164, with 61 referred to the Enforcement Team or Conduct Supervision Team in the past year. Clement Cheung, the IA’s CEO, has emphasised the IA’s supervisory focus on ensuring the insurers’ fair treatment of customers in the coming years.

Link to IA annual report 2022-2023

Link to Insurance Asia article

Link to Asia Insurance Review article

21 February 2024

The IA has warned insurers of the inherent risks related to premium financing as this is particularly sensitive to changes in interest rates. The surge in interest rates in the past two years has brought severe volatility to the market which has impacted both policyholders and the insurance market.

Mr Marty Lui, the IA’s head of Long Term Business (Acting), highlighted the risks involved in premium financing:

  • during periods of low interest rates, policyholders are able to use premium financing to benefit from the spread between their policy returns and bank loans and also amplify their returns through leveraging; however, this magnifies risks and potential losses;
  • current high interest rates have already increased the cost of borrowing, and at the same time decreased policy returns as the majority of products purchased through premium financing are now participating products, which offer returns which are not guaranteed and are subject to the investment performance of the insurers and also have longer break-even periods, further aggravating the risks involved in premium financing.

In view of these risks, the IA and the Hong Kong Monetary Authority (HKMA) jointly issued guidance to the industry in 2022 to clarify the supervisory requirements for premium financing. These requirements, which took effect in 2023, are targeted at insurers and insurance intermediaries and focus on enhancing disclosure and improving affordability assessment to protect policy holder interests.

In 2022, the IA received 28 complaints about premium financing, and that figure rose to 50 in 2023. Concerns were raised over the lack of risk disclosure by intermediaries during the selling process and misrepresentation of policy terms and loan rates. 

In 2023, premium financing activities slowed down substantially; this business declined from 43% of the total market in 2022 to 21% in 2023 (including a multi-year record low of 9% in Q4 of 2023). This may indicate that amid rate hikes the public has become relatively conservative towards premium financing.

The IA and the HKMA have joined forces for another round of inspections related to premium financing to examine compliance with the new requirements and assess market trends. They will share their observations from these inspections with the industry in due course and in the meantime, and to enhance policyholder protection, have issued a reminder about the cautious use of premium financing.

Link to IA article

Link to Business Insurance article

Link to Asia Insurance Review article


21 February 2024

The Green and Sustainable Finance Cross-Agency Steering Group (CASG) has made significant updates to its website to serve as a primary source of information on green and sustainable finance for banks, corporations and the general public.

Some key enhancements include:

  • the digitalisation of the Climate and Environmental Risk Questionnaire for Non-listed companies: this feature streamlines the SMEs’ reporting process and facilitates their exchange of consent-based data with financial institutions;
  • the development of greenhouse emissions calculation and estimation tool: SMEs may compute their emissions accurately using real activity data and financial institutions may use the estimation tools to gauge the SMEs’ emissions linked to their portfolios.

The updates to the CASG website reflect the efforts to solidify Hong Kong’s leading position in green and sustainable finance in regional and global arenas.

Link to IA press release

Link to Insurance Business article

Link to Insurance Asia article

27 February 2024

Prudential Hong Kong Limited (Prudential) has entered into a partnership with Shenzhen New Frontier United Family Hospital (UFH), the first Hong Kong-funded private hospital in Shenzhen, to introduce a medical expenses direct billing service for its customers.

Under these direct billing arrangements, eligible Prudential customers will be able to consult Hong Kong doctors in Shenzhen and enjoy a streamlined claims process. Prudential will directly settle pre-approved medical expenses with UFH upon completion of treatment.

The arrangements are intended to eliminate the inconvenience of travelling between Hong Kong and the Mainland for medical treatment.

In response to demands for quality cross-border medical services, it is believed that more members of the industry will follow suit and engage in cross-border innovative collaboration with medical services in the Greater Bay Area.

Link to Insurance Business article

Link to Asia Advisers Network article

Link to Insurance Asia article

28 February 2024

According to GlobalData, the Hong Kong personal accident and health (PA&H) insurance sector is expected to experience a compound annual growth rate of 7.4%, with gross written premiums increasing from HK$21.4 billion in 2024 to HK$28.5 billion by 2028.

This expected growth is driven by an increased health awareness following the COVID-19 pandemic, and a resumption of travel activities following the relaxation of pandemic-related restrictions.

A recovery in tourist arrivals from Mainland China has also supported the growth of health and travel insurance. Mainland customers have also been drawn to Hong Kong for its advanced medical services and shorter waiting time. Hong Kong insurers also offer features such as additional coverage for family members and the flexibility to purchase higher coverage for specific types of illness which are not generally available in insurance policies offered in Mainland China.

The demographic changes in Hong Kong may also be a pivotal factor in driving the PA&H insurance growth. In 2024, it is projected that 30.8% of Hong Kong’s population will be aged 60 or above. By 2030, the figure may reach 35.5%.

With the surge in the cost of local health and medical services in 2023, 2024 is likely to see continued medical inflation and an increase in health-related risks, which will potentially lead to higher health insurance prices.

Link to GlobalData article

Link to Asia Insurance Review article

28 February 2024

The 2024-25 Budget speech by the Financial Secretary, Hon Paul MP Chan references the following matters of relevance to the insurance industry:

  • Insurance-linked securities (ILS): The Hong Kong Government is promoting Hong Kong as an ILS issuance hub by establishing a dedicated regulatory regime and launching a pilot grant scheme. To date, the government has facilitated the issuance of four catastrophe bonds in Hong Kong, and will continue to attract more issuing institutes to Hong Kong, while nurturing talent and propelling the industry’s development;
  • Trade financing: Mainland enterprises with operations in Hong Kong can also utilise export credit insurance provided by the Hong Kong Export Credit Insurance Corporation; and
  • High value-added maritime services: The Hong Kong Government has expressed interest in studying further enhancements of tax concession measures for marine insurance.

IA’s response

The IA welcomed the 2024-25 Budget and has said it is “ready to provide sophisticated risk management solutions for large corporations with a global footprint.”

The IA also said it will continue to “promote Hong Kong as a platform for issuance of insurance-linked securities and a conduit for international investors to gain access to the Mainland market, in particular the Guangdong-Hong Kong-Macao Greater Bay Area.”

Link to IA press release

Link to 2024-25 budget speech

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