Public Disclosure of the Insurers

The key objectives of public disclosure requirements on insurers are to align with international regulatory benchmarks and enhance market discipline and transparency by providing meaningful and useful information to the general public.

The Insurance Authority (“IA”) plans to implement the public disclosure requirements in 2026 through the enactment of a piece of subsidiary legislation under the Insurance Ordinance (Cap. 41). The relevant legislative proposals have already gone through the public consultation and the relevant consultation conclusions published in August 2025.

Applicability

Public disclosure requirements are applicable to all authorised insurers for disclosing audited financial statements and disclosure statements, except for the following:

Marine insurers
Captive insurers
Special purpose insurers
Insurers which have obtained the approval under Rule 88 of the Insurance (Valuation and Capital) Rules

Lloyd's is required to disclose its audited financial statements only.

What is disclosure statement?

Upon expected implementation of the statutory requirements on full public disclosure requirements in 2026, insurers must provide information annually in a disclosure statement. HK insurers and designated insurers¹ disclose information on company level, while non-HK insurers (other than designated insurers) disclose information on Hong Kong branch level. Disclosure statement is prepared based on regulatory valuation and capital framework under the Insurance Ordinance (as compared with audited financial statements prepared under generally accepted accounting principles/financial reporting standards).

¹ If, in the opinion of the IA, a non-HK insurer carries on a majority of its insurance business in or from Hong Kong, the IA may, by a written notice served on the insurer, designate the insurer as a designated insurer.

What information can I find in the disclosure statement?

Disclosure Statement Template can be found at Appendix D of consultation conclusions. A disclosure statement generally includes the following:

Section	Information to be disclosed
Company Profile	Name, nature of business, place of business operations, and corporate structure of the insurer
Corporate Governance Framework	Details of the insurer's governance framework
Financial Position	Balance sheet under Risk-based Capital (“RBC”) regime, with components of long term business, participating business (being part of long term business), and/or general insurance business Balances of the components should be consolidated and offset at the insurer’s total level of balance.
Investments	Valuation assumptions and methods relating to the investments held by the insurer
Insurance Liabilities	Insurance liabilities for long term business and/or general business by lines of business, along with the description of relevant valuation assumptions and methods
Financial Performance	Breakdown of the components of performance analysis (including premiums, claims and investment returns) for long term business, participating business (being part of long term business) and/or general business Breakdown of the underwriting results by line of business for general business
Capital Adequacy	Prescribed capital amount (“PCA”) and its risk components, capital base and its capital components, and the ratio of capital base to PCA (please refer to An Overview of RBC for explanations about PCA and capital base) Under the Insurance Ordinance, insurers are required to maintain capital base that is adequate to cover PCA. Each insurer is expected to maintain an adequate capital level reflecting its own appetite on capital management, taking into account factors including the risk profile, business strategy, and ability to absorb losses in order to withstand adverse events.
Risk Management	Risk appetite, risk governance framework, and risk management of insurance and investment risks

Interim Arrangement

As an interim arrangement, the IA has also required insurers vide circular dated 8 August 2025 to disclose the quantitative part of the disclosure statements for the first financial year of implementing RBC Regime (i.e. the 2024 financial year). The disclosure of information in the 2024 financial year shall include financial position, insurance liabilities, and capital adequacy.