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September 30, 2025

Insurance Claim Denied in Hong Kong: Your IARB and IA Rights

Guide to appealing insurance claim denials in Hong Kong via Insurance Authority, IARB, and internal complaints.

Insurance Claim Denied in Hong Kong: Your IARB and IA Rights

An insurance claim denied Hong Kong isn't final. Hong Kong has a strong regulatory system with independent dispute resolution. This guide shows you exactly how to appeal, escalate, and fight your way to a fair outcome.

The Insurance Authority (IA) oversees all insurers and brokers. They've created strict rules for fair claims handling. The Insurance Appeals Tribunal (IARB) is your independent reviewer.

Here's your complete roadmap.

Your Rights in Hong Kong's Insurance System

Hong Kong's system is well-established and fair. Here's what protects you:

Insurance Authority (IA): Regulates all insurers and brokers. Sets binding standards for conduct and claims handling.

Insurance Appeals Tribunal (IARB): Independent body that reviews insurance disputes. Can overturn denials and award compensation.

Insurance Ordinance: Legal framework requiring fair treatment and clear disclosure.

Financial Services and the Treasury Bureau: Oversees insurance regulation.

Right to Appeal: Every insurer must have a formal complaints process.

IFEC (Insurance & Deposit Protection Council): Provides consumer information and handles some complaints.

The system gives you multiple paths to challenge unfair denials. Use them.

Step 1: Get a Full Written Explanation

Your insurer must provide a detailed written explanation for any denial.

This explanation must:

  • Quote the specific policy clause or condition cited
  • Explain how your claim doesn't meet that requirement
  • Reference the evidence reviewed
  • Show they considered your full circumstances
  • Provide information about how to escalate

If the explanation is vague, that's already a sign of weakness. Push for clarity.

Keep this letter. It's the foundation of your appeal.

Step 2: Lodge Your Internal Complaint

Every insurer in Hong Kong must have a documented complaints procedure. Use it formally.

Timeline: The insurer must respond within 30 calendar days with a full decision.

How to Complain:

  1. Contact the insurer's Complaints Department
  2. State: "I am lodging a formal complaint about the denial dated [date]"
  3. Include: policy number, claim number, date of denial, why you believe it's wrong
  4. Attach new evidence: medical reports, doctor's letters, policy analysis, treatment guidelines
  5. Send by registered mail or email with delivery confirmation

What to Include:

  • Clear statement that you're formally complaining
  • Reference to the denial letter and date
  • Specific policy clauses supporting your position
  • Medical evidence or documentation
  • Calm, factual explanation of why the denial is wrong

Response Timeline: The insurer has 30 calendar days to respond. If they don't, you can escalate immediately.

Possible Outcomes:

  • Claim approved (success!)
  • Denial upheld with detailed explanation
  • Partial settlement or compromise

If the insurer upholds the denial, they must inform you about escalation options (IARB and IA).

Step 3: Appeal to IARB (Insurance Appeals Tribunal)

If the insurer rejects your complaint, you can escalate to the Insurance Appeals Tribunal—Hong Kong's independent dispute resolver.

What is IARB? The Insurance Appeals Tribunal is an independent body with authority to review insurance disputes. It's impartial and has the power to overturn insurer decisions.

Who Can Use IARB:

  • Any person or business (with insurable interest)
  • Claims involving individuals only (not corporations in some cases—check IARB rules)
  • Most types of insurance disputes

How to Appeal:

  1. Request IARB appeal form from the insurer (they must provide it) or visit iarb.org.hk
  2. Complete the appeal form with your details, claim details, and reasons for disagreeing
  3. Attach: insurer's complaints response, denial letter, medical evidence, policy document, any supporting materials
  4. Submit to IARB

What IARB Can Do:

  • Review the insurer's decision independently
  • Overturn the denial if they find the insurer was wrong
  • Order the insurer to pay the claim
  • Award compensation for distress or inconvenience
  • Award interest

IARB's Authority: IARB decisions are binding on the insurer. Once they rule in your favour, the insurer must comply and pay.

Timeline: Most cases are resolved within 6-12 months. Simpler cases can be faster.

Cost: IARB charges a small filing fee (usually HKD 1,000-3,000 depending on claim value). This is minimal compared to the potential recovery.

Step 4: Escalate to the Insurance Authority (IA)

If you have concerns about insurer misconduct (beyond just the claim decision), you can also complain to the Insurance Authority.

IA's Role:

  • Regulates insurer conduct
  • Investigates complaints about misconduct
  • Can fine insurers for violations
  • Can require corrective action

When to Use IA:

  • If you believe the insurer handled your complaint unfairly
  • If the insurer breached IA rules or the Insurance Ordinance
  • If the insurer has engaged in unfair conduct throughout the process

How to Complain to IA:

  1. Visit the Insurance Authority website (ia.org.hk)
  2. Complete their complaint form
  3. Provide details of the issue and evidence
  4. Submit

IA investigations can be slower than IARB, but they're useful if there's systemic misconduct.

Common Denial Reasons in Hong Kong—And How to Challenge Them

"Pre-existing condition": The insurer says your condition existed before the policy. Counter with: doctor's letter with dates, medical records, evidence you disclosed what was required, policy wording showing how "pre-existing" is defined.

"Not medically necessary": The insurer claims the treatment wasn't clinically justified. Fight back with: doctor's letter explaining medical necessity, medical guidelines supporting the treatment, evidence similar treatments are approved.

"Exclusion applies": The insurer says a policy exclusion covers your situation. Counter with: policy wording that contradicts this interpretation, medical evidence showing the treatment was for a covered condition, industry standards interpretation.

"Claim form incomplete": Ask exactly what's missing. Then provide it. If the insurer is vague about what's needed, that's a weakness in their position.

"Insufficient documentation": Similar to above. Demand specificity. Then provide the documents requested. Document what the insurer asked for and what you provided.

Evidence That Strengthens Your Appeal

Build a strong evidence pack:

Medical Evidence:

  • Doctor's letter addressing the denial reason specifically
  • All medical records, test results, imaging
  • Evidence the condition was serious or progressive
  • Clinical guidelines (local or international) supporting the treatment
  • Evidence the treatment was delivered and cost

Policy Analysis:

  • Full policy document with relevant clauses highlighted
  • Schedule of benefits (if separate)
  • Comparison showing similar claims approved
  • Any communications from the insurer about coverage

Documentation:

  • Proof you notified the insurer within required timeframes
  • Communication history (emails, letters, notes from calls)
  • Timeline of events
  • Proof of how you submitted the claim

Expert Opinion:

  • Doctor's detailed letter supporting necessity
  • Specialist opinion if applicable
  • References to treatment guidelines
  • Evidence of standard medical practice

Writing Your IARB Appeal

Your IARB appeal must be clear, specific, and well-organized.

Structure:

  1. Summary of what happened
  2. Why you believe the insurer's decision is wrong
  3. Reference to specific policy clauses supporting your case
  4. Medical evidence and expert opinion
  5. What outcome you're seeking
  6. All supporting documents organized and referenced

Keep it professional. Facts only. Let the evidence speak.

ClaimBack can analyse your case and write your appeal letter in minutes — Start Free →

We'll analyze your denial, your policy, your medical records, and Hong Kong regulations, then generate a professional appeal that IARB reviewers take seriously.

Timeline for Appeal in Hong Kong

  • Internal complaint: 30 days
  • IARB appeal: 6-12 months
  • Total: 7-13 months in most cases

This may seem long, but IARB takes time to review cases properly. During this period, try to avoid paying disputed bills.

What If You Used a Broker?

If you purchased through a broker or agent, they also have responsibilities. If they:

  • Misrepresented coverage
  • Failed to disclose exclusions
  • Recommended an unsuitable policy
  • Failed to act on your instructions

...then the broker/agent shares liability. You can also complain about them to the IA.

Pre-Appeal Verification Checklist

  • I have my denial letter with detailed reasoning
  • I have filed an internal complaint and received the response
  • I have gathered all medical evidence and records
  • I have my full policy document
  • I have identified relevant policy clauses supporting my position
  • I have organized all evidence chronologically
  • I know IARB's website and contact details (iarb.org.hk)
  • I have drafted a clear, factual appeal
  • I have budget for IARB filing fee (small amount)

Hong Kong's regulatory system is designed to ensure fair claims handling. Use it.


Disclaimer: ClaimBack provides AI-generated appeal assistance for informational purposes only. ClaimBack is not a law firm and does not provide legal advice. Always review your appeal letter before sending and consider professional advice for complex or high-value claims. Regulatory processes vary — always verify current procedures with your insurer or regulator.


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