No. There is no specific regulation governing the sale of insurance through online platforms. Note however the following related to online sale of insurance products: (i) the Insurance Authority ("IA") launched a pilot scheme, Fast Track, on 29 September 2017 to expedite applications for new authorization to carry on insurance business in or from Hong Kong using solely digital distribution channels; and (ii) the IA issued the Guideline on The Use of Internet for Insurance Activities ("GL8") which came into effect on 26 June 2017 to draw the attention of insurers, insurance intermediaries and other groups regulated by the IA to the special points they need to be aware of when conducting any kind of insurance-related activities, whether wholly or partially, over the Internet.

Yes. The Fast Track regime and GL8 are relevant to the sale of insurance, whether through mobile applications or other online platforms.

Three key regulatory requirements relevant to the distributions of products online under GL8 are: (i) the products must be sold by the insurers, insurance intermediaries or other groups authorized under the Insurance Ordinance to carry on insurance business in or from Hong Kong; (ii) the collection, processing and storing clients’ personal information over the Internet must comply with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong); and (iii) the sale of insurance products online must comply with the Electronic Transactions Ordinance (Cap. 553 of the Laws of Hong Kong).

There is no specific insurance regulation governing e-KYC. However, GL8 provides that insurers must have a prudent underwriting policy to process insurance applications submitted via the Internet. In particular, they must take practicable measures to ascertain the true identity of their clients.

Yes, but the conclusion of the insurance policies/contracts must comply with the relevant provisions of the Electronic Transactions Ordinance (Cap. 553 of the Laws of Hong Kong) in matters concerning, inter alia, digital signatures, presentation or retention of information in its original form and retention of information in electronic records.

No. There is no specific regulation governing the advertising of insurance products through online platforms or the use of aggregators. However, if the advertising of insurance products is conducted through a third party online platform and the third party is considered to be carrying out insurance regulated activities, the third party may be required to obtain the requisite insurance license.

There are no specific requirements governing customer service if the insurers sell their products online. There are only general requirements under GL8 relating to customer service, including but not limited to the following: (i) the sales materials or illustrations displayed on the Internet must contain accurate and up-to-date information which is written in plain language; (ii) the potential policy holders must be provided with all the necessary information; (iii) the potential policyholders must be given an opportunity to access the full wording of the relevant insurance policy before the sale is completed; (iv) any electronic insurance policies or documents must be received in a readable and retainable form by the policy holder; and (v) information on the appropriate channels for complaints must be provided.

There is no such obligation imposed yet.

For new insurers to conduct online sales using solely digital distribution channels, they are required to apply for authorizations from the IA through the Fast Track regime. For existing insurers to conduct online sales, they may do so with their existing insurance licenses.

No. Insurance intermediaries may conduct online sales with their existing insurance intermediary licenses.

No. There is no difference on the commission rates paid between online sales and other means.

No. Insurers are generally not subject to any limitations under their insurance licenses to engage in online insurance sales. Therefore, whether or not the insurers would be deemed as offering or selling insurance products online by engaging intermediaries to do so should not be a regulatory concern.