An insurer's salaried direct sales staff advise customers on the coverage of the insurer's products as its representatives. They:
Answer: need individual insurance agent licences. The insurer's own exemption does not extend to its agents, and the law does not distinguish employees from non-employees; such staff need individual agent licences.Why not the others:• need no licence, as they are employees: employment status is no defence.• are covered by the insurer's own exemption: the exemption does not extend to its agents.• need technical representative (broker) licences: they do not act for brokers.Watch out: Assuming salaried staff are outside the licensing regime.Rule: Employees who give regulated advice for the insurer need to be licensed as individual agents.Source: IA P1 Study Notes 2024 Ed. §6.2.1, p.6/13-6/14; Insurance Ordinance (Cap. 41) s.64G (e-Legislation, checked 31 Oct 2026)
Assuming salaried staff are outside the licensing regime.
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