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Swiss Chinese Law Association — Geneva

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Legal Observatory / Finance and Payments

Legal Update China Hong Kong SAR Regulatory guidance

Hong Kong Outlines Insurance Regulatory Initiatives, Infrastructure Capital Relief, and ILS Legislative Plans

Financial Secretary Paul Chan delivered a speech detailing insurance sector statistics, capital requirement changes for infrastructure investments, cross-border ETF rules, and planned protected cell company legislation.

What Changed

  • Capital requirements for eligible infrastructure investments in Hong Kong and Mainland China will be lowered starting at the end of 2026.
  • Mainland insurance funds received regulatory backing to invest in eligible Hong Kong-listed ETFs through Southbound Stock Connect.
  • Hong Kong is exploring draft legislation for a protected cell company structure to streamline insurance-linked security arrangements.

At the Asian Insurance Forum 2026 on 13 November 2026, Hong Kong Financial Secretary Paul Chan outlined major regulatory initiatives and market developments designed to enhance the resilience of the local insurance sector and support Hong Kong's role as an international risk management centre under the National 15th Five-Year Plan.

Hong Kong currently hosts approximately 160 authorised insurers, including six of the top ten global insurance groups. Gross premiums reached HK$827 billion last year, rising 30 per cent, and grew over 35 per cent in the first half of this year. As of late June 2026, two insurers have completed re-domiciliation under Hong Kong's new corporate re-domiciliation regime.

key developments and regulatory measures highlighted include:

- Capital and Regulatory Frameworks: The Risk-Based Capital regime took effect in July 2024 to align capital requirements with risk profiles. Public disclosure rules implemented in May 2026 require covered insurers to publish annual reports on financial standing, capital adequacy, and risk management.

- Infrastructure Investment Relief: Effective from the end of 2026, Hong Kong will lower capital requirements for eligible infrastructure investments in Hong Kong and Mainland China, releasing underwriting and investment capacity for projects including the Northern Metropolis.

- Cross-Border Investment Access: Following an August decision by the National Financial Regulatory Administration, Mainland insurance funds are supported to invest in eligible Hong Kong-listed exchange-traded funds (ETFs) via Southbound Stock Connect.

- Specialty Insurance & Risk Pools: A marine specialty risk pool launched in November 2025 by five insurers now protects over 1,000 vessels against war and related risks. The government and Insurance Authority are also facilitating the Hong Kong Shipowners Mutual Assurance Association to expand international business locally.

- Insurance-Linked Securities (ILS) and Legal Reforms: Eight ILS have been issued in Hong Kong, including seven catastrophe bonds and one sidecar covering Mainland offshore wind farm risks. To lower setup costs and operational complexity, Hong Kong is exploring legislation to introduce a protected cell company structure for multi-transaction ILS issuances.

- Artificial Intelligence Sandbox: Insurers are testing generative AI tools under an expanded sandbox launched in March 2026, alongside the Insurance Authority's AI Cohort Programme.

Who May Be Affected

Authorized insurers in Hong Kong, Mainland insurance asset managers, infrastructure project sponsors, shipowners, and insurance-linked security investors.

Cross-Border Context

Connects Mainland China insurance capital to Hong Kong-listed ETFs via Southbound Stock Connect, covers Mainland infrastructure projects, and provides catastrophe and marine specialty risk pooling internationally.

What to check next

  • Monitor legislative proposals and public consultation materials regarding the protected cell company structure for insurance-linked securities in Hong Kong.
  • Review regulatory guidance issued by the Insurance Authority on lowered capital requirements for eligible infrastructure investments effective end of 2026.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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