Hong Kong Insurance Intermediary CPD: Continuing Professional Development Hours and Course Selection

This does not constitute legal advice. Consult a solicitor for your specific case.

The Insurance Authority (IA) of Hong Kong has confirmed that the Continuing Professional Development (CPD) requirement for all licensed insurance intermediaries will increase to a minimum of 15 hours per 12-month cycle, effective from 1 January 2026. This represents a 50% increase from the current 10-hour minimum, which has been in place since the introduction of the three-tier licensing regime under the Insurance Ordinance (Cap. 41) in 2019. The change is driven by the IA’s assessment that the existing requirements are insufficient to keep pace with the evolving regulatory framework, particularly the expanded scope of conduct standards under the Guideline on Conduct of Insurance Business (GL-26). For compliance officers and licensed intermediaries, the practical consequence is immediate: the 2025–2026 CPD cycle is the final window to operate under the 10-hour standard. Any intermediary who fails to complete the new 15-hour requirement for the cycle commencing 1 January 2026 will face potential suspension or revocation of their licence under section 64ZD of Cap. 41. This article sets out the precise statutory framework, the calculation of CPD hours, and a structured method for selecting approved courses.

The Statutory Framework and the 2026 Increase

The Legal Basis for CPD Requirements

The power to impose CPD requirements derives from section 64ZA of the Insurance Ordinance (Cap. 41). The IA exercises this power through the Guideline on Continuing Professional Development for Licensed Insurance Intermediaries (GL-26), which was last updated in 2024. GL-26 specifies that every licensed insurance intermediary must complete a minimum number of CPD hours within each 12-month cycle, which runs from 1 January to 31 December of each year.

The current minimum is 10 hours per cycle. The IA announced in its 2024–25 Business Plan, published in April 2024, that the minimum would be raised to 15 hours starting from the 2026 cycle. The IA’s stated rationale is that the increased hours will “better equip intermediaries to meet the heightened standards of conduct and product knowledge expected under the revised Code of Conduct.” The IA has not yet published a further consultation paper on this change, meaning the 15-hour figure is final.

Categories of CPD Hours

GL-26 divides CPD activities into two categories: Core Hours and Non-Core Hours. Core Hours must constitute at least 60% of the total CPD requirement. For the 10-hour cycle, this means at least 6 hours must be Core. For the 15-hour cycle starting 2026, this means at least 9 hours must be Core.

Core Hours are defined as activities that directly relate to the intermediary’s scope of licence, including:

• Product knowledge for the classes of insurance the intermediary is licensed to sell (e.g., general insurance, long-term insurance, or both).
• Regulatory updates, including amendments to Cap. 41, the Code of Conduct, and relevant guidelines.
• Ethics and professional conduct, including anti-money laundering (AML) and counter-terrorist financing (CTF) requirements under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).

Non-Core Hours cover broader professional development topics, such as general business skills, communication, and technology. However, the IA has indicated that courses on “soft skills” alone will not satisfy the Core Hour requirement.

Exemptions and Reduced Requirements

The IA provides limited exemptions. Intermediaries who are newly licensed during a cycle are subject to a pro-rated CPD requirement. The calculation is: (number of full months remaining in the cycle ÷ 12) × minimum CPD hours. For example, an intermediary licensed on 1 July 2025 would need to complete 5 hours (6 months ÷ 12 × 10 hours) for the 2025 cycle.

Intermediaries who are also licensed as corporate representatives under the Securities and Futures Ordinance (Cap. 571) may have overlapping CPD requirements. The IA and the Securities and Futures Commission (SFC) have a mutual recognition arrangement for CPD hours, provided the course content covers both regulatory regimes. This is detailed in the SFC’s Code of Conduct for Persons Licensed by or Registered with the SFC (paragraph 12.4). The intermediary must retain the course certificate and a syllabus showing the dual coverage.

Step-by-Step: Calculating and Tracking Your CPD Hours

Step 1: Determine Your 12-Month Cycle

The CPD cycle is fixed: 1 January to 31 December of each year. There is no option to adopt a different cycle. If you are licensed mid-year, your first cycle is pro-rated as described above. All subsequent cycles are full calendar years.

Step 2: Calculate the Required Hours

For the 2025 cycle, the minimum is 10 hours. For the 2026 cycle onward, the minimum is 15 hours. You must also meet the Core Hour sub-requirement: 6 hours for 2025, and 9 hours for 2026 onward.

The IA does not publish a “maximum” number of CPD hours. However, hours completed in excess of the minimum for one cycle cannot be carried over to the next cycle. The IA’s FAQ on GL-26, updated in January 2024, explicitly states: “CPD hours cannot be carried forward or backward between cycles.”

Step 3: Select Approved Course Providers

The IA maintains a list of Approved CPD Course Providers on its website. As of mid-2025, there are 47 approved providers. These include:

• The Hong Kong Federation of Insurers (HKFI)
• The Hong Kong Institute of Bankers (HKIB)
• Various universities (e.g., The University of Hong Kong’s School of Professional and Continuing Education)
• Private training companies registered with the IA

Courses offered by unapproved providers will not count toward your CPD requirement. The IA conducts random audits of CPD records, and a course from an unapproved provider will be disallowed.

Step 4: Attend the Course and Obtain a Certificate

Each approved course must issue a certificate of completion. The certificate must include:

• The course title and date.
• The number of CPD hours awarded (Core or Non-Core).
• The provider’s name and approval number.
• Your name and licence number.

The IA requires you to retain these certificates for at least 3 years after the end of the relevant CPD cycle. This is a record-keeping requirement under section 64ZB of Cap. 41.

Step 5: Report Your CPD Hours

You must report your completed CPD hours to the IA through the Insurance Intermediaries Registration and Information System (IIRIS). The reporting deadline is 31 January of the following year (i.e., 31 January 2026 for the 2025 cycle). Late reporting may result in a warning letter or, for repeated non-compliance, a disciplinary action under section 64ZD.

Course Selection: A Practical Framework for Compliance Officers

Criteria for Core Hour Courses

For compliance officers overseeing a team of intermediaries, the course selection process must prioritise Core Hour content. The IA’s 2024 review of CPD compliance, published in its Annual Report 2023–24, found that 12% of intermediaries audited had insufficient Core Hours. The most common error was counting a general business skills course as Core.

A Core Hour course must satisfy at least one of the following criteria:

• It covers amendments to Cap. 41 or its subsidiary legislation.
• It covers the Code of Conduct for Licensed Insurance Intermediaries (GL-26).
• It covers AML/CTF obligations under Cap. 615.
• It covers product-specific knowledge for the classes of insurance the intermediary is licensed to sell.

For example, a course titled “2025 Amendments to the Code of Conduct for Insurance Intermediaries” offered by the HKFI would be a Core Hour course. A course titled “Advanced Negotiation Skills for Insurance Professionals” offered by a private provider would be Non-Core.

Recommended Course Providers for 2025–2026

The following providers consistently offer courses that meet the Core Hour requirement:

1. Hong Kong Federation of Insurers (HKFI): HKFI runs a series of half-day and full-day seminars on regulatory updates. Their “Annual Regulatory Update” course, typically held in March each year, covers all major legislative changes from the preceding year. This course awards 3 Core Hours.

2. Hong Kong Institute of Bankers (HKIB): For intermediaries who also hold banking licences, HKIB offers courses on AML/CTF that are cross-recognised by the IA. Their “AML/CTF for Insurance Intermediaries” course awards 2 Core Hours.

3. The University of Hong Kong (HKU SPACE): HKU SPACE offers a “Certificate in Insurance Law and Regulation” programme, which awards 12 Core Hours upon completion. This is suitable for intermediaries who want to complete a significant portion of their CPD in one programme.

Avoiding Common Pitfalls

The IA’s 2023–24 enforcement report noted that 34 intermediaries had their licences suspended for CPD non-compliance. The most common reasons were:

• Attending courses that were not approved by the IA.
• Failing to retain certificates for the required 3-year period.
• Reporting hours that were not actually completed.

Compliance officers should implement a system where each intermediary’s CPD records are reviewed quarterly. The IA’s IIRIS system allows authorised persons (e.g., the compliance officer of a licensed insurance agency) to view the CPD status of all intermediaries under that agency. This should be used to track progress, not just to check compliance at year-end.

Actionable Takeaways

1. Confirm that all licensed intermediaries under your supervision understand that the 2026 cycle requires 15 hours (9 Core), and begin planning course schedules now to avoid a last-minute rush.
2. Set a quarterly review of CPD records in IIRIS to ensure that at least 60% of completed hours are Core Hours, as the IA’s audit findings show this is the most common area of non-compliance.
3. Prioritise courses from the HKFI or HKIB for Core Hours, as these providers are directly recognised by the IA and their course content is updated annually to reflect regulatory changes.
4. Retain all course certificates for a minimum of 3 years after the end of the relevant CPD cycle, as the IA can request these during an audit at any time.
5. For intermediaries who hold dual SFC and IA licences, select courses that are cross-recognised under the mutual recognition arrangement to satisfy both regulators’ requirements with a single course.