IA insurance broker company licence

01 / BUSINESS SCOPE

Business Scope and Application Value

An insurance broker company licence is suitable for businesses that compare cover on behalf of clients, arrange insurance and provide related insurance services; it is not authorisation to underwrite insurance as an insurer. The application should be accompanied by arrangements for a responsible officer approved by the regulator, capital and net assets, professional indemnity insurance, client accounts, and internal controls for genuine operations. Information verified as of 3 November 2026.[1][3]

• Within the approved business line, act as an agent for policyholders or prospective policyholders to negotiate or arrange insurance contracts and provide related regulated advice. The business is positioned to assist clients in identifying their protection needs and selecting solutions, not to assume insurance risk itself or guarantee that claims will be approved.[1][2]
• You can plan the scope of services according to your capabilities, covering general insurance, long-term insurance or long-term insurance with investment-linked business; it is not necessary to apply for all categories at once. Clarifying your products and target customers first helps align the responsible persons’ experience, business representative examination eligibility, sales processes and ongoing training resources.[5]
• Formal licensing and records in the register enable clients to verify the company’s identity and provide a regulatory basis for discussions with insurers about broker arrangements. However, being licensed does not mean that an insurer will necessarily enter into an agreement or that a bank will necessarily open an account. Nor does it mean that the Insurance Authority endorses the company’s commercial returns or the performance of any particular product.[1][4]
• Capital, professional indemnity insurance and a system for segregating client money provide financial and operational safeguards for client services. Businesses can use these foundations to develop ongoing services such as renewals, policy reviews and claims assistance, but must still disclose conflicts of interest, explain the scope of their services and properly retain client instructions and the basis for their recommendations.[2][3]

02 / ENTRY REQUIREMENTS

Entry Conditions and Core Requirements

• The applicant must be a company and must clearly disclose its directors, direct and indirect controllers, and ultimate control arrangements. The Insurance Authority will assess fitness and properness, financial soundness and organisational competence. A certificate of incorporation, proof of capital or ready-made licensed-company shell alone cannot substitute for the substantive requirements for conducting business.[1][4]
• Appoint at least one person in charge approved by the Insurance Authority, and provide sufficient authority, personnel and resources to discharge supervisory duties. The company and each individual proposing to conduct regulated activities must separately satisfy the applicable licensing or approval requirements. A company licence alone does not allow employees without the appropriate licence to solicit insurance.[2][4]
• The company must continuously meet the thresholds of at least HKD 500,000 each in paid-up share capital and net assets. Whether the threshold is met should be assessed using net assets adjusted under Chapter 41L, not merely the bank balance; rent, salaries, insurance premiums, and system expenses during the preparation period should all be included in the funding stress assessment.[3]
• For the first 12 months of business, the professional indemnity insurance limit of liability must be at least HK$3,000,000. Thereafter, it must be calculated as twice the insurance broking income for the preceding 12 months and compared with HK$3,000,000; the higher amount applies. The rules cap the income multiple calculation at HK$75,000,000 and require the limit of liability to be automatically reinstated at least once. [3]
• The excess under professional indemnity insurance cannot be agreed arbitrarily: it must generally not exceed 50% of net assets at the end of the financial year immediately preceding the policy period. For the first 12 months of business, it is limited to 50% of paid-up share capital at the start of the policy period. The policy should cover liability for defaults in regulated activities, and coverage should be reviewed when the business changes. [3]
• Prepare a Hong Kong bank account for client monies in accordance with the Insurance Authority’s application guidance. If client money is received or held, comply with client account rules, segregation of funds and reconciliation at least once a month. Even if clients are expected to pay insurers directly, do not state on your own that the bank account and all client-money requirements are automatically waived. [3][4]
• Establish corporate governance, sales supervision, complaint handling, conflicts of interest, staff training and information security arrangements proportionate to the scale of the business. Ongoing business must also implement applicable anti-money laundering requirements. The arrangements should specify responsible persons, operational steps and inspection records; an unimplemented generic compliance manual is not sufficient. [4][6]

03 / PEOPLE & GOVERNANCE

Shareholders, directors and compliance personnel

• The responsible person must first be approved by the Insurance Authority before assuming responsibility for supervising the company’s relevant business. Prepare their complete résumé, education and professional qualifications, insurance and management experience, and current positions, and assess each item under GL23. A nominal appointment, lending of qualifications or use of a consultant title is not equivalent to effective management.[2][6]
• Employees who solicit, negotiate or arrange insurance, or provide regulated advice, should hold a representative (broker) licence for the appropriate business type and be appointed by the company. If administrative staff go beyond purely clerical work and actually explain or recommend insurance, reassess whether they are engaging in regulated activities.[1][2]
• General insurance business representatives usually need to pass the Insurance Principles and Practice and General Insurance papers. Long-term business representatives usually need to pass the Principles and Practice and Long Term Insurance papers. Those involved in investment-linked long-term insurance must also pass the relevant investment-linked paper. Any examination exemption should be verified qualification by qualification against the recognised qualifications under GL23.[5]
• An individual applicant must also prove that their academic qualifications meet the level recognised by the IA and truthfully disclose criminal records, disciplinary sanctions, bankruptcy and other fit-and-proper matters. Mainland Chinese qualifications may require verification through CHSI, notarisation or confirmation from the school. Holding a degree or passing an examination does not mean that the remaining fit-and-proper assessment is automatically satisfied.[7]
• Sales review, compliance oversight, client account and complaint-handling personnel should be arranged according to the complexity of the business, with reporting lines clearly defined for part-time or outsourced work. Outsourcing may assist with execution, but does not transfer the regulatory responsibilities of the company or its responsible persons. Concurrent roles that involve conflicts of interest should be assessed separately. [2][4]
• Individual licensees generally must complete 15 hours of continuous professional training during each assessment period, including at least 3 hours on ethics or regulations. From 1 August 2025, responsible officers of brokerage firms must also complete at least 2 hours of training related to management responsibilities and control functions; these hours may count towards the 3-hour and 15-hour requirements above. [8]

04 / CAPITAL & PREMISES

Capital and business address requirements

Financial resources and sources of funds

The company must continuously maintain paid-up share capital of at least HKD 500,000 and net assets of at least HKD 500,000, satisfying both requirements at the same time; this does not mean that an additional total of HKD 1 million must be paid in. Net assets must be adjusted under Chapter 41L, excluding intangible assets and other items; the minimum threshold is not the total start-up budget, and losses may cause net assets to fall below the requirement.[3]

Statutory share capital, net assets, liquid capital and other financial resources are not the same concept. Capital is not a government fee or consultancy fee, and must not be conflated with client assets or reserve funds.

Hong Kong Business Address and Substantive Operations

• Provide the IA with a genuine and contactable business address that can support actual business operations, and explain arrangements for client meetings, document storage, staff supervision and information systems. The official application overview reviewed does not prescribe a uniform minimum office area. An area or fit-out standard recommended by a consultant should not be presented as a statutory threshold.[4]
• Ensure that client discussions, identity documents and policy information are appropriately protected, with clear access permissions and arrangements for retrieving records. Whether a shared office or remote working is suitable cannot be determined solely by reference to an address-service contract; confidentiality, supervisory capacity and the scale of the specific business should also be assessed. [4][6]
• The lease, proof of address and business registration details should be consistent with the actual applicant entity and business arrangements. Systems and files should be available for company audits and regulatory inspections. Arrange for continuity of information and customer services before relocation, and notify the IA promptly after the move in accordance with company information change requirements.[9]

05 / APPLICATION DOSSIER

Application Document Checklist

• The company information pack should include incorporation and business registration documents, the articles of association, director information, a group and shareholding structure chart, and a clear tracing of the ultimate controllers. Where there are corporate shareholders, multi-tier shareholdings or overseas companies, provide the relevant incorporation documents, evidence of control relationships and any required supplementary forms.[7][9]
• Financial documents should evidence paid-up share capital and adjusted net assets, and include the source of capital, bank records and applicable financial statements. The preparation budget and revenue forecast explain the ability to continue as a going concern; projected commissions must not be treated as assets already realised, nor customer-account funds as freely disposable company funds.[3]
• Prepare the professional indemnity insurance terms, liability limits, deductibles and automatic reinstatement arrangements, and attach client account-opening information and bank notification records. The insurance documents should match the proposed business; submitting only a quotation that does not reflect the scope of cover and key conditions is insufficient.[3][4]
• Information for responsible officers and proposed business representatives should cover proof of identity, employment history, verification of academic qualifications, qualifying examination or basis for exemption, experience statements and fit and proper disclosures. The employment history should describe specific responsibilities, business lines and management authority; listing only job titles or general years of service is not advisable. [5][7]
• The business plan should set out the service categories, client sources, product scope, insurer partnerships, and fee and commission model, together with client agreements, sales procedures, referral monitoring, and complaint and record-management systems. Each system should correspond to actual personnel and systems, so that the written materials remain aligned with the operating plan.[4][6]
• Open a commercial-entity applicant account through the Insurance Intermediaries Connect platform. Prepare the A2a for signature and the Business Registration Certificate, then submit the application as a company together with the latest document checklist. A case may require an S-series disclosure form or additional documents. This checklist is a preparation framework and does not replace the IA’s current official checklist. [7][9]

06 / APPLICATION ROADMAP

Application process and required time

The Insurance Authority’s published processing targets are 12 weeks for a new company application and 4 weeks for a responsible officer application, in both cases starting once all required documents are complete. Incomplete or returned applications are not included. These are not guaranteed licence-approval periods; company establishment, bank account opening, insurance, qualification checks and requests for further documents require additional time. A fixed total number of months cannot be promised.[4]

1. Step 1: First determine the scope of general insurance, long-term insurance and whether investment-linked business is included, and describe the target customers, products and sales channels. Identify whether the actual work performed by employees and referral persons constitutes regulated activity, then decide the company business lines and individual licensing arrangements rather than simply copying someone else’s licence structure. [1][5]
2. Step 2: Finalise the company and shareholding structure, responsible officers and business representative candidates, and conduct preliminary checks of qualifications and background information. In parallel, assess the sources of funds, operating budget and regulatory capital buffer. If personnel experience is not commensurate with the proposed business, adjust the scope or strengthen the team before applying.[4][6]
3. Step 3: Put in place business premises, client accounts, professional indemnity insurance and internal control systems. Turn procedures for handling client funds, the basis for recommendations, commission disclosure, complaint handling and data security into specific processes. Retain evidence of account-opening and insurance arrangements, and check that the company’s financial position continuously complies with Chapter 41L.[3][4]
4. Step 4: An authorised representative submits A2a through the Insurance Intermediaries Connect portal. Once permission is granted to establish a corporate applicant account, submit the company application and supporting documents. The IA first assesses overall completeness and will notify the applicant to pay once it considers the application substantially complete. Do not mistake the submission date for the start of the approval target period. [4][7]
5. Step 5: Respond to the Insurance Authority’s enquiries about personnel, controllers, financial matters and operational arrangements, and supplement explanations or revise systems where necessary. Approval of responsible persons, individual licences and the company’s scope of business must be progressed in coordination. 12 weeks and 4 weeks are official service targets, not a guarantee of approval that can simply be obtained by adding the periods together.[4]
6. Step 6: After approval, check the licensed business types, conditions and register particulars before commencing the corresponding regulated activities. Establish a calendar for licence renewals, audits, insurance renewals, capital monitoring and training. Do not commence business before obtaining the appropriate licence or approval on the grounds that an application is pending or approval is expected.[1][9]

07 / ACQUISITION & CHANGES

Acquisitions, Changes to Shareholders and Directors, and Completion

• The acquisition target should be a company that is actively operating and holds valid licences, not a standalone licence that can be bought and sold or detached from a company. Before the transaction, check the Insurance Authority register, approved business lines, licence conditions and expiry date, and review regulatory correspondence, outstanding remediation and litigation or complaints.[1][2]
• Changes in shareholding and control usually involve a post-event notification under section 64ZZD; it should not be stated broadly that all share transfers invariably require prior approval. The specific licence conditions, changes of responsible persons and other transaction arrangements must still be checked to determine whether separate approval or regulatory communication is required, and the fitness and properness of new directors and controllers must be assessed.[9][10]
• Financial due diligence should focus on adjusted net assets, paid-up share capital, client account shortfalls, commission receivables and clawback liabilities, tax, and undisclosed liabilities. Sample-check bank reconciliations, audit reports and premium settlement records. Do not treat client money, book goodwill or uncollectible commissions as distributable assets.[3]
• Review the claims basis, notified circumstances, exclusions and change-of-control clauses in the professional indemnity insurance, and confirm whether historical service errors remain covered. The fact that insurance has not lapsed does not mean that all past risks are covered. Where necessary, confirm continuation or run-off cover arrangements with the insurer.[3]
• Check whether the responsible person and key business representatives will remain, and confirm any change-of-control restrictions in insurer arrangements, client service agreements and commission contracts. Client relationships and insurer channels are not guaranteed to continue simply because shares have been acquired. Closing conditions should cover verification of personnel, insurance, bank authorisations and business continuity. [2][4]
• The transaction documents should allocate risks relating to historical breaches, client money shortfalls, commission clawbacks and claims, and set out notification and remediation responsibilities before and after completion. These contractual protections are commercial and legal arrangements; they are not a substitute for Insurance Authority approval of the transaction or a guarantee that the licence will be renewed after the acquisition.[9][10]

Shareholders, Directors and Other Material Changes

• If the company’s name, business address, telephone number or email address changes, it must notify the relevant authority under section 64P within 14 days, using the N4 procedure applicable to the company. A change of name or business address also requires updated business registration and evidence of the relevant Companies Registry filing; updating the website alone is insufficient.[9]
• If a person becomes or ceases to be a director or controller of a company, the company must notify the IA in writing within 1 month after the change occurs and comply with the N5 and supporting-document requirements. This deadline differs from the 14-day period for general changes of information and should not be conflated with a blanket 14-day deadline in an acquisition guide. [9][10]
• A controller is not limited to a registered shareholder. The term also covers a person who directly or indirectly holds or controls not less than 15% of the issued share capital, is entitled to not less than 15% of the voting rights, or ultimately controls the company's management. The analysis should look through the group, trusts and other control arrangements; checking only the licensed corporation's register of shareholders is insufficient.[10]
• Appointment of a responsible person requires prior approval from the Insurance Authority; an already licensed company may use A3. The principal must notify the Insurance Authority within 14 days after terminating the appointment of a responsible person or a business representative. For a proposed appointment of an existing licensed intermediary, notice of intent to appoint must generally be given at least 14 days in advance. [2][9]
• Adding a company line of business requires an A7 application for approval and a check of the corresponding qualifications of the responsible officer and business representative; a separate process applies to individual lines of business. Changes to shareholders, personnel or business structure may trigger multiple requirements at the same time. Filing with the Companies Registry must not be treated as a substitute for procedures with the Insurance Authority.[9]

08 / ONGOING COMPLIANCE

Post-approval maintenance and ongoing responsibilities

• After daily operations and significant expenditure, continue to monitor paid-up share capital, adjusted net assets and operating cash, rather than checking only at the application or year-end. If the capital buffer is weakening, address losses and capital-injection arrangements promptly. Client money, anticipated commissions and assets that cannot be recognised must not be counted as available capital.[3]
• Maintain professional indemnity insurance that meets the requirements on an ongoing basis. Before renewal, recalculate the limits of indemnity based on revenue and review the excess and automatic reinstatement clauses. When expanding the business, making an acquisition or adding services, confirm the scope of cover and arrangements for notifying historical claims; an unexpired policy alone does not establish that cover is adequate.[3]
• Any customer money held or received must be segregated from the company’s own funds. Customer accounts must be used for receipts and payments as required, and account records must be reconciled with bank balances at least once in every calendar month. Investigate and resolve discrepancies promptly, retain evidence of reconciliations and reviews, and do not use customer premiums to cover operating expenses.[3]
• Within 6 months after the end of each financial year, submit to the Insurance Authority the audited financial statements, the auditor's report on those financial statements, and the auditor's report on ongoing compliance with the financial rules. This deadline differs from tax filing arrangements. If there is genuine special difficulty, apply in advance for an extension under section 79; do not assume an extension has been granted.[11][12]
• Under Chapter 41L, keep books and records sufficient to reflect the financial position, client money and compliance with the Rules for at least 7 years. Financial statements must disclose general and long-term business brokerage income, the total cash in client accounts and premiums payable. The auditor’s opinion does not relieve the company of its responsibilities.[3]
• The continuous professional training assessment period runs from 1 August to 31 July of the following year. A return must generally be filed by 30 September; training evidence must be retained for at least 3 years after the end of the assessment period. Excess hours cannot be carried forward, and responsible officers must also meet the current training requirements relevant to their management duties.[8]
• Arrange for the company to renew its licence by the expiry date shown on the licence, submit R4 through Insurance Intermediaries Connect and apply at least 45 days before expiry. The IA has charged the relevant application and notification fees since 23 September 2024. It should not be stated that paying a fixed annual fee alone entitles a company to hold a licence permanently or to automatic renewal. [9][12]
• Continually review fit and proper status, the basis for sales recommendations, conflicts of interest and complaint handling, and supervise referral channels and employees’ actual conduct. For ongoing business, implement customer and beneficial-owner identification, risk assessment and suspicious transaction handling. Business records should support audits, complaint investigations and IA inspections. [4][6]

09 / FREQUENTLY ASKED

Frequently asked questions

10 / OFFICIAL REFERENCES

Official references and information verification

Information compilation date:3 November 2026The regulatory websites below are used to verify applicable laws, the latest forms, fees and registration status. Primary legislation, current requirements of the competent authorities and case-specific decisions take precedence.

Prepared by Rengangyongsheng (Hong Kong) Limited; professional explanation provided by Business Manager Tang Shangyong (Drew). This does not constitute legal, tax or investment advice for any specific case.