Digitalization in Insurance Guide | Japan | Asia Pacific Insurance

Is there any specific regulation governing the sale of insurance through online platforms?

Yes. The Ordinance for Enforcement of the Insurance Business Act and the Comprehensive Guidelines for Supervision of Insurance Companies have specific provisions which regulate the matters to be considered when the Financial Services Agency (FSA) examines for approval the statement of business procedures containing sales of insurance products through the Internet.

Is the sale of insurance through mobile applications subject to the same requirements as the online sale?

Yes.

Set out three key regulatory requirements for the distributions of products online or through mobile applications.

Three key regulatory requirements are: (i) the insurer must establish a system which enables the insurer to provide information or explanation at the same level as face-to-face channels; (ii) the insurer is required to make sure that an applicant for an insurance contract is a legitimate party to sign a contract; and (iii) the insurer must take security measures to prevent the use of the Internet from causing a leak of information concerning insurance policies and policyholders.

Do the current insurance regulations in your jurisdiction allow the KYC process be done online or electronically? If so, what are the key requirements?

Yes, KYC process can be done online or electronically. Under the Comprehensive Guidelines for Supervision of Insurance Companies, the insurer is required to make sure that an applicant for an insurance contract is a legitimate party to sign a contract.

Do the insurance regulations permit insurance policies/contracts to be concluded through digital means? For example, through a “click-through” or “e-signature”, without any wet signature.

Yes, insurance policies may be concluded through digital means such as a click-through.

Is there any specific regulation governing the advertising of insurance products through online platforms or the use of aggregators?

Advertising of insurance products through online platform is subject to the same regulation as advertising through other means. If an aggregator receives compensation from an insurer or an insurance solicitor and recommends or explains any particular insurance product, such action may be deemed as insurance solicitation and be subject to the regulations regarding insurance solicitation.

Are there any customer service requirements if the insurers sell their products online?

Under the Comprehensive Guidelines for Supervision of Insurance Companies, the insurer must establish a system which enables the insurer to provide information or explanation at the same level as face-to-face channels, including showing the customer the content of the insurance policy and attention attracting information electronically in order for the customer to be fully aware that such information is important.

If an obligation is imposed on insurers to allow customers to amend or update their policies online, are there any specific regulatory requirements governing that process?

There is no such obligation imposed yet.

Are insurers required to apply for specific insurance licenses in order to conduct online sales?

No. Any specific license is required for insurers to conduct online sales.

In order to conduct online sales, are insurance intermediaries required to apply for any specific insurance licenses?

No, any specific license is required for insurance intermediaries to conduct online sales.

Are there specific requirements on the commission rates paid to insurance intermediaries for online sales? Please specify if these rates are different from the rates applicable in the case of insurance sale through other means.

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

Where the insurers do not engage in online insurance sales themselves, but engage intermediaries to do so, would the insurers be deemed as offering or selling insurance products online?

No.

Asia Pacific Insurance

Japan

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