Context: Buying insurance in an app in three minutes is a smooth experience, but when an insured event happens, customers finally ask the question they should have asked first: who issued this contract, and what exactly is the selling platform in the law’s eyes?
Legal Basis and How It Applies
Distributing insurance via technology platforms creates no new type of insurance: the contract is still issued by the insurer, which bears the claim duty under the Law on Insurance Business 08/2022/QH15 (effective 1 January 2023). What changes is the sales channel: a tech platform that advises, introduces and arranges contract conclusion for customers must act as an insurance agent (a certified individual agent, or an agency organisation) under the insurer’s mandate, or limit itself to a marketing channel passing customers to a qualified party. A platform that collects premiums and advises on benefits without agent status is distributing outside the law.
Responsibility to customers follows the real role, not the marketing label: the insurer pays claims when events occur and answers for product content; agents and distribution platforms answer for the truthfulness of advice and information given in the sales step. AI-chatbot advice is not prohibited, but the insurer cannot plead ‘the AI advised wrongly’ to escape responsibility — the advisory tool is part of the insurer’s own sales process, and customers must always have a human channel for questions and complaints. Bought online or traditionally, claim rights are identical — the difference lies in the quality of advice evidence on record.
Application in Practice and Common Pitfalls
Before buying insurance in an app, customers should check three things inside the application: the issuing insurer’s name, the platform’s agent status, and the full policy wording rather than a benefit summary. Missing any one of the three is reason enough to stop, because in a claim dispute these are the first three documents requested.
Action Checklist
The steps below turn the analysis above into concrete work:
- First, test your own situation against this ground: Distributing insurance via technology platforms creates no new type of insurance: the contract is still issued by the insurer, which bears the claim duty under the Law on Insurance Business 08/2022/QH15 (effective 1 January 2023).
- Record the application point specific to this case instead of copying conclusions from another case: A platform that collects premiums and advises on benefits without agent status is distributing outside the law.
- Prepare the evidence and file relating to the following point before dealing with authorities or partners: Before buying insurance in an app, customers should check three things inside the application: the issuing insurer’s name, the platform’s agent status, and the full policy wording rather than a benefit summary. Missing any one of the three is reason enough to stop, because in a claim dispute these are the first three documents requested.
- Answer the question clients ask most directly with this conclusion, and keep it on file: Advising customers and arranging insurance contracts must be done with insurance-agent status mandated by the insurer under the Law on Insurance Business 08/2022/QH15. A platform that only markets and refers customers needs no agent status, but crossing into advice and premium collection requires it.
Frequently Asked Questions
Does selling insurance via an app require an insurance-agent licence?
Advising customers and arranging insurance contracts must be done with insurance-agent status mandated by the insurer under the Law on Insurance Business 08/2022/QH15. A platform that only markets and refers customers needs no agent status, but crossing into advice and premium collection requires it.
Is online insurance compensated like traditional insurance?
Identical. A contract issued by an insurer carries the same value and claim duty whether bought via app, agent or counter. The online channel’s risk is not lower benefits but customers glossing over exclusion clauses because the purchase flow is too fast.
Is AI-chatbot insurance advice lawful?
Not prohibited, but responsibility does not shift to ‘the AI’: the chatbot is a tool in the insurer’s and agent’s sales process, so wrong chatbot advice remains their responsibility. Customers must have a human channel to re-confirm material advice before concluding the contract.
This article has been quality-reviewed by the FLAW AI Legal Council