There is no standalone insurtech licence in Vietnam: a foreign-invested digital insurance platform must place itself in one of the legal capacities the Law on Insurance Business 08/2022/QH15 already provides — most commonly an insurance brokerage enterprise, or an insurer if it wants to underwrite products itself.
Legal basis
- Law on Insurance Business 08/2022/QH15: establishment conditions for insurance brokerage enterprises, legal capital, licensing by the Ministry of Finance, and insurance distribution through electronic channels.
- Decree 46/2023/ND-CP guiding the Law on Insurance Business: licensing dossier detail and management personnel conditions for brokerage enterprises.
What conditions apply to FDI insurtech and digital insurance brokerage?
The core conditions for a foreign-invested insurance brokerage enterprise are: the corporate form prescribed for brokerage enterprises; minimum legal capital of VND 8 billion for broking both direct and reinsurance, or VND 4 billion for one line only (direct or reinsurance); management and executive staff meeting education and insurance experience standards, with insurance brokerage certificates for prescribed positions; and a charter, brokerage procedures, risk governance and technology systems fit for online distribution. The point insurtech models most often misread is the capacity boundary: a platform may advise, offer and collect only within its brokerage or agency capacity; designing risk cover and promising claims payment like an insurer without an insurer licence is out-of-scope activity and heavily sanctioned. Digital in digital brokerage is a distribution channel, not a new legal capacity.
Where is the brokerage licence obtained? Can insurance be sold online?
The establishment and operation licence of an insurance brokerage enterprise is issued by the Ministry of Finance on a dossier evidencing legal capital, personnel and organisational conditions. On online sales: electronic insurance distribution is legally recognised — insurers and distributors may offer and conclude insurance contracts by electronic means subject to customer identification, full product information and transaction data retention for audit. A licensed brokerage insurtech platform may therefore sell insurance fully online, but the digital journey must reproduce every duty of the traditional channel: needs-based advice, disclosure of exclusions, and confirmation that the customer understood the product before premium collection.
Is insurance commission capped?
There is a management frame: brokerage and agency commission is limited by maximum rates set by the Ministry of Finance for each line and product, on the basis that insurers may not pay commission above the frame to compete on non-technical grounds. For a digital platform the compliance point is presentation: commission may not be disguised as a platform fee charged to customers on top of the published premium, and every customer charge must be transparent in the sales journey. An FDI insurtech revenue model must therefore be designed inside the permitted commission frame plus lawful service fees under its registered capacity, rather than assuming the free negotiation of ordinary technology sectors.
Frequently asked questions
What conditions apply to FDI insurtech and digital insurance brokerage?
Establish an insurance brokerage enterprise under the Law on Insurance Business 08/2022: legal capital of VND 8 billion (direct plus reinsurance broking) or VND 4 billion (one line), management and prescribed staff holding brokerage certificates, and qualifying procedures and technology. Insurtech is a digital channel, not a separate legal capacity.
Where is the insurance brokerage licence obtained?
From the Ministry of Finance, which issues establishment and operation licences for insurance brokerage enterprises on dossiers of legal capital, personnel and organisational conditions under the Law on Insurance Business 08/2022 and Decree 46/2023/ND-CP.
Can insurance be sold online?
Yes. Electronic distribution is recognised subject to customer identification, full disclosure of product terms and exclusions, and transaction data retention for audit — the digital journey must perform the full advisory duties of the traditional channel.
Is insurance commission capped?
Yes: brokerage and agency commission is limited by maximum rates set by the Ministry of Finance per line and product. A digital platform may not charge customers extra fees under another name beyond the published premium, and revenue must be designed within the permitted commission frame.
This article has been quality-reviewed by the FLAW AI Legal Council