September 2026
Clickbait – the existence of the word reflects the ever-increasing consumption of information through our screens. Look around you next time you are on the MTR: it’s a forest of bowed heads and swiping fingers.
For marketers, that endless scrolling is pure opportunity to sell. But capturing that opportunity is not easy. You only have a few seconds to hook your scroller's attention. So you need that one eye-catching statistic or headline to make them pause and click.
We’re sure you know what we mean: “Transform your body with military calisthenics or tai-chi walking!” “Learn any language in only 15 minutes a day!”
Marketers of insurance products are, alas, becoming familiar with this tactic of “baiting” you into “clicking” to “learn more” with that one statistic or promise that will hook your attention: a three-figure fulfilment ratio; a double-digit growth rate on non-guaranteed benefits and dividend payouts; a slashed break-even timeline.
“The statistic is true, so what’s the problem?” is often the marketer’s first line of defence when the regulator questions this manipulative strategy. “Our product may only be two years old, but so far it has a fulfilment ratio of 100%. And yes, we did have that growth rate during that one year, on that one particular dividend payout.”
Maybe so, but it’s still a misleading, manipulative and an unfair way of capturing a customer’s attention. So misleading, in fact, as to amount to a clear misrepresentation.
Your company may have achieved a 100% fulfilment ratio in the first two years of the product's life. Big deal! Dividend/bonus benefit payouts for a new product are typically low in the early years, and any insurer failing to hit those numbers would be drastically underperforming (and not worthy of calling themselves “insurer”). And as every insurer knows, when it comes to long-term participating policies, the early year dividend/bonus benefits are sometimes negligible — it’s the later years that matter. The fulfilment ratio in the early years provides limited indication that performance will continue over the life of the policy, yet that is precisely what the marketer is trying to mislead the customer into thinking. Stop it!
And one year’s growth for a dividend payout? Come on! This says nothing about growth over the long term, even though that is precisely what the marketer is inaccurately trying to hint at. Again, stop it!
“Oh, but it isn’t misleading”, the marketer will say, putting forward their second wave of defence. “We make the position perfectly clear… after the customer clicks ‘learn more’. All we are doing with our eye-catching statement is initiating a conversation, and once the customer clicks, they will be given a full and fair presentation, so they have a complete understanding of the policy before making a purchase decision.”
Unfortunately, this second line of defence doesn’t wash either.
Hooking a customer’s attention with a cherry-picked piece of clickbait does more than just initiate a conversation. It shapes the psychological lens through which customers will view every subsequent piece of information fed to them on the subject. By anchoring initial expectations to an exceptionally positive outlier, the marketer establishes an immediate optimism bias. Subsequent footnote qualifications or dense brochure disclaimers are rarely sufficient to dismantle this initial impression. The misrepresentation — and the distraction it brings — is complete the moment that one eye-catching, misleading fact is retained in the customer's mind, nudging them toward completion of the purchase based on distorted expectations.
Marketers know this behavioural psychology. That’s why they do what they do.
Look at General Principle 1 in the Codes of Conduct for Licensed Insurance Agents and Licensed Insurance Brokers: inaccurate, misleading, or deceptive statements aimed at inducing a client to enter into an insurance policy are strictly prohibited. Breach that, and you are breaching key provisions in Section 90 of the Insurance Ordinance (IO) - the core conduct requirements. Key Persons in Control Functions for Intermediary Management take note. It’s your job to establish controls and processes to keep your intermediaries compliant in their regulated activities, which includes preventing attempts to induce customers into buying insurance policies through misleading marketing activities.
Guideline 10: Guideline on the Corporate Governance of Authorized Insurers (“GL 10”) also imposes an obligation on authorized insurers to adopt fair treatment of customers as an integral part of their business culture, strategies, and internal controls (GL10, para 10.1). As part of this, adequate and clear information must be made available to customers before, during, and after the point of sale.
Attempting to hook a customer’s attention to “learn more” with clickbait that instills a misleading impression from the outset is the very essence of unfair customer treatment. Any insurer that does this will very quickly “learn more” about how the Insurance Authority’s regulatory procedures work!
To keep the digital marketing of insurance products firmly on the right side of the regulatory line, here are five essential rules for an insurer to embed into its product approval and governance frameworks:.
Most insurers subject proposed campaigns to multiple internal sign-offs. Business units look at conversion rates; Operations assess delivery and efficiency; Finance looks at cost; Compliance ticks off legal boxes; Risk checks exposure.
Yet, too often, one crucial perspective is missing in the governance sign-off process: the customer’s view. Compliance, Risk, and Business may plead that their sign-off takes account of this, but does it really? Or are they merely evaluating it from the insurer’s perspective to keep the campaign compliant, profitable and risk-managed?
The truth is that, often, nobody in the governance process is asking the most critical common-sense question: What mental impression does a customer form within three seconds of seeing this ad?.
At least one signing-off unit — ideally Compliance, Risk, or a dedicated Customer Champion team — must be formally mandated to perform a "Customer Viewpoint Assessment". This requires stepping outside of legal fine print and evaluating the campaign's overall impression in that split second when the ad appears on a user's feed:
If the honest answer is "yes", the campaign should fail sign-off and be sent back to the drawing board — regardless of how many footnotes and disclaimers Compliance suggests adding.
Furthermore, a Customer Viewpoint Assessment may actually help the insurer discover what it is that its customers really want to know. This will provide a far better, and fairer, starting point for designing any campaign.
If a statistic makes it into the headline, its corresponding limitations, key assumptions, and risks must sit right alongside it, with equal visual prominence. Marketers often push back on this by saying: “Customers don’t want to be bothered with all that information.”
Our job as the regulator is to protect customer interests – to stand on their side and often in their shoes. So our response to marketers is this: Don’t treat customers like idiots! Treat them fairly! Give them the information they need to make a decision that directly impacts their budget and life, so that the decision is genuinely right for them.
In insurance marketing, if the customer has to search for the catch, the presentation is inherently misleading and unfair. Don’t do this.
Social media ads open the door, but in Hong Kong, insurance intermediaries often close the deal. Insurance agents and insurance brokers must be trained not only on product technicalities, but on how to identify and immediately dismantle any distorted expectations a customer obtains from an ad.
Note: this does not give marketers free rein to publish whatever they want to hook attention, safe in the knowledge that an intermediary will fix it later. Rather, it ensures that unpredictable customer impressions are caught, managed, and corrected at the point of advice.
Furthermore, governance should include a feedback loop. If intermediaries report that clients are consistently misunderstanding a campaign's headline, the insurer must actively tweak or withdraw the promotion. The same principle applies to customer complaint trends.
Trustworthy marketing should not rely on an isolated headline statistic. Always provide direct, low-friction access — such as clear web links or QR codes — leading customers straight to comprehensive historical metric tables to give them the full picture (for example, complete fulfilment ratio histories).
Good insurers do not fear full, unselective disclosure. They show performance overall — warts and all — so customers can make genuinely informed decisions.
“Show me the incentive and I’ll show you the outcome”, famously said the late Charlie Munger of Berkshire Hathaway fame.
We saw this play out with intermediary commissions for participating policies, where high upfront first-year commissions with minimal tail commission over-prioritized initial sales and de-prioritized ongoing servicing — ultimately prompting the Insurance Authority to introduce commission spreading requirement.
The same principle applies to how an insurer incentivizes its internal marketers. Measure their performance solely by click - through rates and lead generation, and you will get misleading clickbait. Reframe marketing success around fair presentation and long-term customer retention, and you align fair customer treatment, regulatory expectations and sustainable business growth.
Anyone who thinks this falls outside the insurance regulatory framework should review paragraph 9.2(c) of GL 10, which explicitly requires an insurer’s remuneration policy to motivate employees to pursue the long-term growth and success of the authorized insurer, demonstrating a clear relationship between performance and remuneration.
Responsible marketing practices in insurance support informed customer financial decision-making and foster the long-term relationship that an insurance policy creates. While the policy itself establishes legal obligations, every marketer must understand that what a customer ultimately seeks is an insurer they can trust with their financial future.
Trust — or distrust — begins with the very first interaction. That is why it is imperative for marketers to get it right from the start: not by focusing on a short-term hook, but by laying the foundation for a long-term relationship built on transparency.
So leave the clickbait to the purveyors of military calisthenics and tai-chi walking. In insurance, there are no quick fixes on offer —only sustainable customer relationships based on fairness and trust.