By Felix Kong｜Licensed Insurance Agent
Looper Insurance Agency Limited (GA1034)
Published: 2026-08-31｜Last updated: 2026-08-31
Among the statutory conditions for a ride-hailing vehicle permit sits one that owners tend to read as paperwork: third party risks insurance that is valid for ride-hailing use. This guide is about that condition alone. What emerges is an awkward gap. The legislation refers to the requirement in four places without ever specifying what product satisfies it, while most Hong Kong private car policies rule out carriage for hire or reward on the use clause page. That gap is where "licensed but uninsured" comes from.
Table of Contents
What the legislation actually requires
The use clause in your own policy
What happens if the policy never changed
Why there is no settled product yet
Three things an owner can do now
FAQ
1. What the legislation actually requires
Four provisions, one requirement:
Provision | What it says |
|---|---|
Ordinance s.55T(3)(f) | An application for a vehicle permit requires third party risks insurance complying with the Motor Vehicles Insurance (Third Party Risks) Ordinance (Cap. 272) that is valid in respect of the private car being used to provide a ride-hailing passenger transport service |
Ordinance s.55U(4)(c) | The Commissioner may impose permit conditions relating to that insurance |
L.N. 61 s.18(3)(f) | The same requirement applies on renewal |
L.N. 61 s.21(3)(f) | The same requirement applies on a change of vehicle |
All four say the cover must comply with Cap. 272 and be valid for ride-hailing use. None of them says whether that means an endorsement to a private car policy or a separate commercial policy. In the regulatory paper the government put to the Legislative Council in May 2026, the word "insurance" appears exactly once. The law fixes the outcome and leaves the form open.
For an owner that has a practical consequence. You cannot wait to be told which product to buy, because nobody intends to tell you. You have to establish whether the policy in your hand is valid for that use.
2. The use clause in your own policy
Hong Kong private car policies generally carry a section headed Limitations as to Use. The common formulation limits cover to social, domestic and pleasure purposes together with the insured's own business or profession, and expressly excludes use for hire or reward, racing, speed testing and the motor trade.
That phrase, hire or reward, is the same legal concept the ordinance uses in section 55A when it defines a ride-hailing passenger transport service as a service for the carriage of passengers for hire or reward. The thing your policy page rules out is the thing the permit lets you do.
Commercial vehicle wordings are not automatically the answer either. They frequently permit the carriage of passengers but qualify it as not for hire or reward. So the distinction is not private car against commercial vehicle. It is whether carriage for reward has been specifically arranged for.
3. What happens if the policy never changed
Two layers, and neither is comfortable.
Compulsory third party cover. Hong Kong law requires valid third party insurance for a vehicle used on the road. If the policy does not respond because the use falls outside the clause, you are carrying passengers uninsured, which brings criminal consequences on top of a civil liability you would fund yourself.
Your own car and your own person. Own damage, theft, fire and driver personal accident under a comprehensive policy all rest on the same contract. Once the use clause is in question, the exposure is not limited to the third party section.
An insurance contract rests on accurate disclosure, and the use of the vehicle is among the most basic underwriting facts. Changing the use without telling the insurer turns a claim into an argument about the basis of cover. That is not a question of being paid less. It is a question of being paid at all.
4. Why there is no settled product yet
As at 31 August 2026, neither vehicle permits nor driver permits have opened for application. Both are expected in the fourth quarter of 2026, with the first platform licences expected in late November.
So the market sits in an odd interim. The statutory requirement for ride-hailing use insurance is already written, yet no owner can hold a vehicle permit and no insurer has a settled basis on which to underwrite and price. In that setting, any offer to quote ride-hailing cover today deserves a direct question about what exactly is being covered.
Our own position, stated plainly: the insurers Looper works with do not currently have a dedicated ride-hailing product. This article is not a sales page. It exists so you know the gap is there before you apply for a permit.
5. Three things an owner can do now
Open the policy and find the use clause. You are looking for Limitations as to Use, and specifically for the words hire or reward. That takes five minutes and settles the main question.
Put one question to your insurer or agent in writing: if this vehicle obtains a ride-hailing vehicle permit and takes bookings through a licensed platform, does the existing policy remain valid? Ask for the answer in writing. That reply is your evidence later.
Settle the insurance before applying for the permit, because the cover is an application condition rather than something arranged afterwards. Renewal and change of vehicle carry the same requirement, so it follows the permit throughout its life.
Worth noting alongside this: the vehicle permit quota is capped at 10,000 for Hong Kong and that figure is set by legal notice. If you intend to apply, the insurance question is not one to leave until last.
FAQ
Q: Does my comprehensive policy already cover ride-hailing?
A: Generally not. The use clause in a Hong Kong private car policy is usually limited to social, domestic and pleasure use plus the insured's own business, and expressly excludes hire or reward. The ordinance defines a ride-hailing service using that same concept, so the cover has to be arranged specifically rather than assumed.
Q: Does the law say which type of insurance to buy?
A: No. Sections 55T(3)(f) and 55U(4)(c) of the ordinance, and sections 18(3)(f) and 21(3)(f) of the Road Traffic (Ride-hailing Service) Regulation, all require third party risks insurance complying with Cap. 272 and valid for the car being used to provide a ride-hailing service. None specifies an endorsement or a standalone policy.
Q: I do not have a permit yet. Should I buy something now?
A: Vehicle permits are expected to open for application in Q4 2026 and the market has no settled ride-hailing product. The useful step now is to check your current wording and obtain written confirmation from your insurer, rather than buying cover whose scope is undefined.
Q: What is the worst case if I take bookings without changing the policy?
A: Two layers. Compulsory third party cover may not respond because the use falls outside the clause, which amounts to driving uninsured and carries criminal consequences. Separately, own damage, theft and personal accident benefits sit on the same policy and may fail with it.
Q: I would only take the occasional booking. Is that different?
A: A use clause turns on the nature of the use rather than how often. The ordinance makes no allowance for occasional bookings either, and the three conditions in section 55C have to be satisfied together.
Next Step
If you intend to apply, the practical move is to send us your current motor policy and schedule. We will read the use clause with you, tell you whether there is room for an endorsement, and let you know the moment a ride-hailing product reaches the market. We will not quote a price for a product that does not yet exist.
For the full picture on licences, vehicle age, the written test and fees, see our practical guide to the new ride-hailing regime.
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Free Quote
Looper Insurance Agency Limited (GA1034) offers a free motor policy check.
Tel: 2633 6813
Email: cs@looperin.com
Website: www.looperin.com
Disclaimer: This article is for reference only and does not constitute legal or insurance advice. Legislative content is subject to the official gazetted version; commencement status is stated as at 31 August 2026. Policy wordings differ, and actual coverage is subject to your own policy terms.
Conclusion
The ordinance asks four times for third party cover valid for ride-hailing use, and never once says what product that means. Meanwhile the use clause in most private car policies rules out hire or reward. That gap is where licensed but uninsured comes from. The practical step now is to read your own use clause and get the insurer's answer in writing. WhatsApp us if you want a second pair of eyes.
Felix Kong
CEO
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