HONG KONG SAR, CHINA Trends and Developments Contributed by: Edwin Northover and Jan Buschmann, Debevoise & Plimpton
Talent Talent remains a concern for Hong Kong insurers, par- ticularly in the actuarial and technology areas, and the industry (with support from the IA) is actively trying to attract additional insurance talent to Hong Kong while also enhancing local education and training in these areas. M&A Although the level of insurance M&A in Hong Kong has been affected by global headwinds, significant activity endures. There is a trend towards consolidation, the key drivers of which include: • the difficulty of achieving profitability without scale; • the new risk-based capital regime; and • an increasing regulatory burden. Buyers typically include existing Hong Kong insurers and other market participants with existing insurance holdings in Hong Kong or other leading jurisdictions.
ance with their filing and notification requirements under the Insurance Ordinance and undertakings given by them. The IA has also recently indicated that it will further review insurers’ approach to the design and sale of participating insurance policies. Referral schemes in relation to the sale of life insurance poli- cies has also been a recent focus. Detailed investigations of perceived regulatory or compliance failures – including investigations involv- ing reports written by law or accountancy firms – are more common now, and the trend towards proactive enforcement can be expected to continue. Re-domiciliation regime Legislative changes permitting the re-domiciliation of insurers (and other companies) to Hong Kong came into effect in May 2025. In relation to insurers, the general rules in the Companies Ordinance are supple- mented by a specific regulatory process and guidance issued by the IA. This mechanism will be particularly relevant to Bermuda-incorporated insurers that write all or a majority of their business in Hong Kong. As such, a number of large international insurance groups are already using the new re-domiciliation mechanism for the re-domiciliation of the Hong Kong branches of their Bermuda subsidiaries.
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