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Hong Kong

Definition of a complaint

Any oral or written expression of dissatisfaction, whether justified or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial service, which:

(1) alleges that the complainant has suffered (or may suffer) financial loss, material distress or material inconvenience; and

(2) relates to an activity of that respondent, or of any other respondent with whom that respondent has some connection in marketing or providing financial services or products, which comes under the jurisdiction of the Financial Ombudsman Service in the UK

Definition of a complainant

The applicable definition of 'eligible complainant' is contained in the FCA Handbook. It is important that managing agents refer to that definition but in summary, 'eligible complainants' are:

  • A consumer
  • A micro-enterprise which employs fewer than 10 persons and has a turnover or annual balance sheet that does not exceed €2 million
  • A small business which is not a micro-enterprise and has and has an annual turnover of less than £6.5 million and employs fewer than 50 persons; or has a balance sheet total of less than £5 million
  • A charity which has an annual income of less than £6.5 million at the time the complaint is made
  • A trustee of a trust which has a net asset value of less than £5 million at the time the complaint is made
  • A person acting for purposes which are outside that person’s trade, business or profession
  • A guarantor

Application of Lloyd’s procedure and local complaint regulations

All valid Lloyd’s insurance policies written.

It is Lloyd’s understanding that there are no local complaints handling rules which apply to Lloyd’s other than a requirement that a complaint procedure exists and is communicated to the customer. It remains the managing agent’s and service company’s responsibility to ensure all local requirements are met, where applicable, in all territories in which they write business.


This is a two stage process. Lloyd’s expects that an acknowledgement is provided to the complainant within 5 business days where possible.

Stage One

The managing agent or their representative has 14 calendar days from receipt of the complaint to issue their stage one response.

Stage Two

If the complainant remains dissatisfied, they can contact Lloyd’s Complaints team. The complaints team will aim to issue a final response within 8 weeks of receipt of the complaint.

If the complainant remains dissatisfied following the final response by Lloyd’s, the complainant may refer their complaint to an appropriate external dispute resolution in Hong Kong (ICB)

EDR scheme and edibility

Insurance Complaints Bureau (ICB) can investigate disputes of personal insurances for monetary value up to HKD 1.2m (Approx. GBP 115,000) for those insurers who are members of the ICB, once the insurer has made a final decision (Lloyd’s HK are a member).

Insurance Complaints Bureau

29/F, Sunshine Plaza

353 Lockhart Road, Wanchai, Hong Kong

The Hong Kong Insurance Authority (IA) may also review a complaint but there are no specified procedures. 

If the complainant is not eligible to escalate their complaint to the ICB in Hong Kong, they may be eligible to refer the complaint to the Financial Ombudsman Service in the UK

Financial Ombudsman Service (FOS).

The Financial Ombudsman Service

Exchange Tower

London E14 9SR

Local Regulatory Reporting Requirements


Lloyd’s Complaints Notice

The new complaints notice for Hong Kong is LSW1894.

Guidance for Managing Agents

Complaints Handling Summary