Insurance Introducer Agreement Template for Hong Kong

An Insurance Introducer Agreement is a specialised contract that allows you to establish formal referral relationships with insurance companies or brokers in Hong Kong while ensuring strict compliance with local insurance regulations. This document creates a legal framework that protects both parties and clearly defines the boundaries of permissible activities under Hong Kong's Insurance Ordinance.

When do you need this document?

You need this agreement when your business wants to refer clients to insurance providers in exchange for commission payments, but you don't hold an insurance intermediary licence. Financial institutions, professional services firms, healthcare providers, and retail businesses commonly use these agreements to generate additional revenue streams. The document is essential if you're a corporate entity seeking to formalise existing informal referral relationships, or if you're an insurance company wanting to expand your distribution network through third-party introducers. You'll also need this agreement when establishing partnerships with banks, accounting firms, or other businesses that encounter clients with insurance needs in their daily operations.

Key legal considerations

The agreement must carefully distinguish between permitted introduction activities and regulated insurance intermediary work that requires licensing under the Insurance Ordinance. You must ensure that introducers only perform basic referral functions and don't provide insurance advice, negotiate terms, or handle premiums. Commission structures need clear definition to avoid disputes, while confidentiality clauses protect sensitive client information. The document should include robust indemnity provisions to protect the insurance company from potential regulatory breaches by the introducer. Anti-money laundering compliance is crucial, requiring introducers to perform appropriate customer due diligence and maintain proper records. Data protection obligations under Hong Kong's Personal Data (Privacy) Ordinance must be clearly outlined, especially regarding how client information is collected, processed, and shared.

Legal requirements in Hong Kong

Under the Insurance Ordinance (Cap. 41), introducers must not engage in regulated activities without proper licensing from the Insurance Authority. The agreement must specify that introducers cannot advise clients on insurance matters, arrange insurance contracts, or handle client money. Compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) requires introducers to implement proper customer identification procedures and maintain transaction records. The Personal Data (Privacy) Ordinance (Cap. 486) mandates that any personal data collection and processing must comply with data protection principles, requiring clear consent mechanisms and security safeguards. The contract must also address ongoing regulatory changes and ensure both parties maintain appropriate professional indemnity insurance coverage as required by Hong Kong regulations.