11.2 Codes of Practice, Fair Dealing and Market Conduct
Key Takeaways
All GIA members observe The Singapore General Insurance Code of Practice (revised 25 October 2022), which applies to general insurance policies issued to individuals.
The Code commits insurers to a quotation within 7 business days, written confirmation of cover by the next working day and policy despatch within 15 business days.
Where a policy has a free-look feature, the Code gives at least 14 business days, but free look does not apply to motor, travel, domestic maid, short-term, renewal or other compulsory insurance.
MAS's Guidelines on Fair Dealing set five outcomes, and boards and senior management are responsible for making fair dealing central to corporate culture.
MAS lifted its outright ban on life insurance rebates in 2002 but discourages rebates as a basis for recommendations; any charge an agent adds to the premium must be disclosed.
11.2 Codes of Practice, Fair Dealing and Market Conduct
Quick Summary: Three layers of conduct standards apply to general insurance. The Singapore General Insurance Code of Practice sets insurers' service standards for individual policyholders. GIA's Code of Practice for Agents sets agents' conduct duties. MAS's Guidelines on Fair Dealing set five outcomes that boards and senior management must deliver. Client premiums must also be handled through proper channels.
The Singapore General Insurance Code of Practice
GIA's Code, in its revised version dated 25 October 2022, aims to give clear, consistent standards and transparency so that individual policyholders can make informed choices. It covers all general insurance policies issued to an individual. All GIA members adopt it. It sits alongside the law and does not give anyone a right to take legal action against an insurer, but customers can complain if insurers fall short.
Core Commitments
Insurers promise to act fairly and reasonably; to make sure the information they give is clear and not misleading; to give enough information and help for an informed decision; and to handle claims and complaints fairly and promptly. Advertising must be clear, fair and not misleading, and must be withdrawn if it turns out to be inaccurate.
Protecting Customers
The Code advises customers to deal only with GIA member insurers, ARB-registered agents, ARB-registered financial advisers, and registered or exempt insurance brokers. Insurers must keep information confidential, comply with the PDPA and the Do Not Call provisions, and not use concealed numbers when calling customers. Conflicts of interest that cannot be avoided must be disclosed before the insurance is arranged.
Key Service Standards
| Stage | Commitment |
|---|---|
| Quotation | Within 7 business days of receiving the required information |
| Confirming cover | In writing by the next working day after instructions to proceed |
| Policy documents | Despatched within 15 business days of confirming cover |
| Mid-term changes | Written confirmation within 7 business days of receiving all documents |
| Refunds | Within 30 business days of the endorsement or cancellation |
| Renewal notice | At least 30 business days before expiry; renewed policy sent within 7 business days |
| Claims | Acknowledge in 3 business days; ask for missing documents in 7; decide within 7 after full information; pay within 10 after settlement is agreed |
| Complaints | Acknowledge in 7 business days; update every 15; appeal to the Chief Executive answered in 15 |
Free Look
For policies with a free-look feature, the Code gives at least 14 business days from receipt of the policy to cancel and get the premium back if no claim has been made, although an administration charge may apply. Free look does not apply to motor, travel or domestic maid insurance, short-term insurance under one year, renewals or other compulsory insurance.
Information on Costs
Insurers must show the premium for each product, any other fees and charges, how the Payment Before Cover Warranty applies, payment deadlines and methods, and, on request, the commissions and other benefits the intermediary receives from the sale.
GIA's Code of Practice for Agents
Under GIARR 2025, every agent, nominee agent and trade specific agent must act with utmost good faith and integrity and must:
- identify themselves as ARB-registered agents and name the insurers they represent, and show proof of registration on request;
- make sure, as far as possible, that the policy is suitable for the customer's needs and resources;
- advise only within their knowledge and recommend specialist advice when necessary;
- explain the essential provisions and draw attention to restrictions, exclusions and conditions;
- not add any charge to the premium without disclosing its amount and purpose;
- tell customers about the Payment Before Cover Warranty, premium deadlines and payment methods;
- explain customers' rights to cancel, to claim, to complain (including to FIDReC) and their protection under the PPF Scheme; and
- acknowledge and respond to complaints within 7 business days, escalating unresolved complaints to their principal insurer.
MAS Guidelines on Fair Dealing
MAS's Guidelines on Fair Dealing set five outcomes. Boards and senior management are responsible for delivering them.
| Outcome | Meaning |
|---|---|
| 1 | Customers have confidence that they deal with financial institutions where fair dealing is central to the corporate culture |
| 2 | Institutions offer products and services that are suitable for their target customer segments |
| 3 | Institutions have competent representatives who provide quality advice and appropriate recommendations |
| 4 | Customers receive clear, relevant and timely information to make informed decisions |
| 5 | Institutions handle customer complaints in an independent, effective and prompt manner |
Handling Client Money
- Brokers: the Insurance Act and the Insurance (Intermediaries) Regulations require registered brokers to keep client premiums in insurance broking premium accounts, separate from the broker's own funds.
- Agents: under the ARB Premium Payment Rules, customers pay premiums directly to insurers, except for limited bundled or affinity transactions (Section 2.3).
- Refunds: refunds due to policyholders must be made within 30 business days of the endorsement or cancellation under the Code.
Rebates and Remuneration
- In 2002, MAS lifted the outright prohibition on life insurance rebates in its former Notice 304, moving towards principle-based regulation. MAS stated that it discourages rebates as the basis for a recommendation and expects advisers to have a reasonable basis for their advice.
- An intermediary therefore must never let a rebate or special concession replace a proper needs-based recommendation, and must not alter the premium without the insurer's authority.
- Customers can ask the insurer to disclose the intermediary's commission and other benefits under the Code.
To which policies does The Singapore General Insurance Code of Practice apply?
Only commercial lines placed through brokers
Only life insurance policies
General insurance policies issued to individuals
Reinsurance treaties between insurers
A customer buys a travel insurance policy and wants to cancel it under a free-look period. What does the GIA Code of Practice say?
Free look does not apply to travel insurance
A free-look period of 14 business days applies
A free-look period of 30 business days applies
Free look applies only if no claim was made in the past year
Which of the following is one of the five outcomes in MAS's Guidelines on Fair Dealing?
Insurers must guarantee a minimum investment return on every general insurance policy
Customers receive clear, relevant and timely information to make informed decisions
Intermediaries must represent at least three insurers
Customers must buy insurance through a broker
Sections you finish are checked off in the contents.