By Felix Kong｜Licensed Insurance Agent
Looper Insurance Agency Limited (GA1034)
Published: 2026-08-25｜Last updated: 2026-08-25

Since the Food Business (Amendment) Regulation 2026 came into effect on 8 May 2026, Hong Kong restaurants can apply for permission to admit dogs. The first phase was capped at 1,000 premises, taking effect progressively from 9 July 2026. Most operators focused on the application window and the HKD 140 licence amendment fee — but the Food and Environmental Hygiene Department's own Guidelines on Good Practices and Behaviour contain one instruction that speaks directly to your balance sheet: notify your insurer. This guide sets out what changes on your risk register once dogs are admitted, and whether your Public Liability (PL) policy and shop package will actually respond.

Table of Contents

1. The scheme in brief

2. Guideline 1.42: notify your insurance company

3. Three new exposures once dogs are admitted

4. What your existing policy does and does not do

5. Refusing entry is your right, not a customer-service failure

6. A five-minute pre-renewal checklist

7. FAQ

1. The Scheme in Brief

Once permission is granted, the operator must display the designated signage at a conspicuous place at the entrance at all times, and post "Notes to Customers" at the entrance or another conspicuous location. Dogs are barred from the food room entirely and may not go on any dining table; whether a dog may occupy a seat is left to the operator's discretion, and at conveyor-belt premises dogs must stay on the floor. Dogs must use single-use, non-plastic, dog-specific utensils, and dog food must be stored completely segregated from food for human consumption. These are licence conditions and guidelines, not suggestions.

On the dog's side: the leash must be no more than 1.5 metres, either securely held by an adult or tied to a fixed structure such as a wall hook or a floor-mounted table leg — not to a movable object like a chair. The requirement applies even where the dog is in a carrier or stroller. Dogs aged five months or above must be licensed and vaccinated against rabies under the Rabies Ordinance (Cap. 421).

2. Guideline 1.42: Notify Your Insurance Company

This is the single line in the guidelines that touches your finances most directly.

Clause 1.42 of the FEHD Guidelines on Good Practices and Behaviour requires restaurant operators to notify their insurance companies that permission has been granted for dogs to enter the premises, and to confirm whether the relevant arrangements and potential scenarios are covered. This is a regulator's written instruction, not an insurer's marketing line. The practical significance is straightforward: if you have not notified, and your policy carries a condition requiring notice of any material change in the nature of the risk, the insurer has grounds to question the basis on which cover was written when a claim arrives.

Note also clause 1.26: where a dog bite incident occurs on the premises, the operator must report it in the prescribed form to the Director within two working days. In practice, that same incident record is your first piece of evidence when you notify your insurer — do both at once rather than waiting.

3. Three New Exposures Once Dogs Are Admitted

3.1 Injured customers → Public Liability

The obvious one: customer A's dog bites customer B, or a dog lunges and a passer-by falls. Liability for third-party bodily injury or property damage is exactly what a PL policy is written for. Note that the defendant is rarely just one party — the dog's owner, whoever was actually controlling the dog that day, and the premises operator may all be named. The dog not being yours does not automatically get you out; the claimant will attack your premises management, seating arrangement and staff response.

3.2 Injured employees → Employees' Compensation

Floor and service staff are the people closest to the dogs. An employee bitten in the course of employment is a work injury under the Employees' Compensation Ordinance (Cap. 282). This is compulsory statutory cover, it is the employer's liability, and it does not wait on the dog owner. Failing to maintain valid EC cover is a criminal offence carrying a maximum fine of HKD 100,000 and two years' imprisonment.

3.3 Hygiene, property and downtime → Property and Business Interruption

A dog soils seating or carpet, breaks tableware, or forces immediate cleaning and disinfection; in an extreme case an incident closes the floor. These losses normally sit with property cover and Business Interruption (BI). But note the trigger: BI usually responds only to insured physical damage to property, and a single dog incident may not clear that bar. This is worth walking through line by line with your insurance agent.

4. What Your Existing Policy Does and Does Not Do

The honest summary: admitting dogs does not change which classes of insurance you need. It changes the exposure sitting inside the classes you already hold. The right first move is not to buy something new — it is to pull out your current policy and schedule and go through the Public Liability limit, exclusions and conditions line by line, then decide whether to raise the limit or add an endorsement.

5. Refusing Entry Is Your Right, Not a Customer-Service Failure

The concern most operators raise is whether refusing a dog invites a complaint. The guidelines are clear that an operator may restrict entry where the dog:

• Is a fighting dog under the Dangerous Dogs Regulation (Cap. 167D) — Schedule 1 lists breeds including the Pit Bull Terrier, Dogo Argentino, Japanese Tosa and Fila Braziliero, and their crossbreeds

• Has been declared a known dangerous dog by a court

• Is over five months old and unlicensed, where the operator asks for proof

• Does not meet the leash requirements (over 1.5 metres, not held by an adult, tied to a movable object)

• Is particularly large, unhygienic, agitated or visibly aggressive

Those five grounds are the backbone of your admission policy. Write it down, post it at the entrance, and train your staff on how to say it. In a later liability dispute, that written policy is your evidence of reasonable care.

6. A Five-Minute Pre-Renewal Checklist

1. Have you notified? Notify your insurer in writing that dogs are permitted, and ask for written confirmation of the position (guideline 1.42).

2. Is the PL limit adequate? Dog-bite awards run well into six figures — see how to set a public liability limit.

3. Any animal-related exclusion? Read the exclusions word for word rather than from memory.

4. Is your EC payroll declaration current? More staff or longer rosters mean an adjustment; under-declaring reduces the claim proportionally.

5. Are your admission policy and staff training written down? Guideline 1.24 requires staff training including emergency response — a verbal rule does not count, and this employers' liability case shows exactly why.

FAQ

Q: Does FEHD really require restaurants to notify their insurer?

A: Yes. Clause 1.42 of the FEHD Guidelines on Good Practices and Behaviour requires operators to notify their insurance company that dogs are permitted on the premises and to confirm whether the arrangements and potential scenarios are covered. Notify in writing (email is fine) and keep the insurer's written reply.

Q: If one customer's dog bites another customer, is the restaurant or the owner liable?

A: The dog owner carries the primary responsibility to restrict and control the dog under the Rabies Ordinance (Cap. 421). In practice, however, an injured claimant commonly sues the owner, the person controlling the dog and the premises operator together, attacking the operator's premises management and staff response. Your Public Liability policy remains the first line of defence.

Q: Does my shop package already include Public Liability?

A: Most SME packages are built around property all-risks cover with liability benefits attached, but limits, exclusions and conditions differ between products. Once dogs are admitted, the question is not whether you have PL — it is whether the limit is adequate, whether an animal exclusion applies, and whether you have notified.

Q: Are hotpot and barbecue restaurants really excluded?

A: Yes. Applications from hotpot and barbecue restaurants, including teppanyaki and Korean barbecue, are not accepted. Applicants must also hold a full restaurant licence and occupy a floor area larger than 20 square metres.

Q: If staff are bitten, does the dog's owner pay?

A: An employee injured in the course of employment is the employer's statutory liability under Cap. 282, and your Employees' Compensation policy responds — you do not wait for the dog owner. Your insurer may later pursue the owner by subrogation, but that does not remove your obligation to the employee.

Next Step

Admitting dogs is a commercial opportunity, not a risk in itself. The risk is a policy still written for a no-dogs world. Send us your current policy and schedule and we will go through the Public Liability limit and exclusions with you, and advise whether an endorsement or a higher limit is warranted.

Related Articles

• A customer's dog bit our waiter: a real employees' compensation claim

• How much public liability cover is enough?

• Shop package or standalone public liability?

• Public Liability Insurance in Hong Kong (English Guide)

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Looper Insurance Agency Limited (GA1034) offers a free policy review and quotations for Public Liability and SME package insurance.
Phone: 2633 6813
Email: cs@looperin.com
Website: www.looperin.com

Disclaimer: This article is for reference only and does not constitute insurance or legal advice. Regulatory content follows the latest published position of the Food and Environmental Hygiene Department and the relevant ordinances; actual coverage is subject to policy terms and conditions.