MACAU SAR, CHINA Law and Practice Contributed by: Carlos Eduardo Coelho, MdME
requirements with regards to the implementation and granting of temporary licences for fintech/insurtech projects. The regulator has also been following mar- ket trends and incentivising stakeholders to develop solutions that would benefit Macau policyholders and improve the provision of insurance-related services. 11. Emerging Risks and New Products 11.1 Emerging Risks Affecting the Insurance Market Catastrophe risks are seen as one of the emerging risks that affect the Macau market. As there have been more significant and severe typhoons in Macau in the past few years, causing huge claims to be made to insurers, the regulator and the current stakeholders (particularly general insurers) are starting to pay spe- cial attention to these matters. Cybersecurity-related risks are currently another top concern for insurers within Macau’s market. In view of the rise of virtual assets, which may typi- cally be used for activities related to money laundering and the financing of terrorism (a risk always raised by the regulator for the insurance industry), the Macau regulator upholds the position of excluding virtual cur- rencies as legal currency and strictly forbids the insur- ance sector from using virtual assets for the payment of premium and claims. 11.2 New Products or Alternative Solutions See 11.1 Emerging Risks Affecting the Insurance Market . 12. Developments in Insurance Law 12.1 Significant Legislative or Regulatory Developments Enactment of the New Insurance Intermediary Activities Ordinance The IIAO came into force on 1 August 2025, replacing the existing MIIO to address the significant growth and changes in the insurance sector in recent years. The IIAO refines the regulatory framework for insur- ance intermediaries, enhancing operational standards
and accountability while increasing penalties for non- compliance. Major key points include: • the introduction of joint liability and a Principal Responsible Approach for better supervision of insurance intermediaries; • the implementation of a Prior Approval and Post- Notification mechanism to enhance regulatory clar- ity for the AMCM; and • the establishment of a comprehensive fit-and- proper assessment for individuals and legal entities in the insurance sector. The new IIAO also extends the supervisory powers of the AMCM and delegates said authority to impose sanctions for offences, including the suspension and revocation of intermediary licences. Enactment of the Guideline on Outsourcing for the Insurance Sector In 2025, the AMCM issued the Guideline on Outsourc - ing for the Insurance Sector , applicable to all licensed insurers, including branches of overseas institutions. The guideline requires insurers to: • perform due diligence; • obtain board approval; • notify the AMCM within 30 days of entering into any material outsourcing arrangement; and • establish appropriate monitoring and internal con- trol mechanisms. The framework highlights that outsourcing does not relieve insurers of their ultimate responsibility for regu- latory compliance, nor does it lessen the accountabili- ty of the board and senior management. Insurers must adopt formal outsourcing policies, conduct compre- hensive risk assessments and due diligence on ser- vice providers, and ensure that contracts address key elements such as service levels, confidentiality, data protection, liability, audit rights and exit strategies. Institutions are also required to maintain business con- tinuity and exit plans, monitor and review outsourc- ing arrangements on an ongoing basis, and promptly report significant incidents (such as operational dis-
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