On 19 Sep 2025, the HKMA and IA issued a circular requiring insurance products with savings features to include 'insurance' in English names and '保險' in Chinese names to prevent consumer confusion. The requirement applies to new products from 1 January 2026 and existing products from 1 January 2027, with ILAS and QDAP exempted, and mandates revisions to all related policy documents and marketing materials.
This article was generated using SAMS, an AI technology by Timothy Loh LLP.
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Requirement for Product Naming
On 19 Sep 2025, the Hong Kong Monetary Authority (HKMA) and the Insurance Authority (IA) issued a circular mandating that insurance products with savings features must include the word 'insurance' in their English product names and '保險' in their Chinese product names. This requirement applies to products designed to meet customers' savings needs or marketed with 'savings' features in brochures or marketing materials, excluding Investment-Linked Assurance Schemes (ILAS) and Qualifying Deferred Annuity Policies (QDAP), which are exempt as widely recognized insurance products. The rule aims to prevent consumer confusion by clearly communicating the product's nature at the point of sale and throughout the policy lifecycle, applying solely to the basic plan and not to riders.
Implementation Timeline and Scope
The supervisory requirement will be implemented in two phases: Phase 1 takes effect from 1 January 2026 for all new in-scope products launched on or after that date; Phase 2 takes effect from 1 January 2027 for existing in-scope products continuing to be sold after that date, requiring insurers to revise all relevant policy documents, marketing materials, and communications. Products ceasing sales before 1 January 2027 are exempt from Phase 2 compliance. Insurers and intermediaries must ensure staff involved in product development, marketing, and compliance are fully informed, and internal controls are robust to uphold fair treatment of customers and their best interests.
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