Licences are due to be issued from November, and HKFI says access to operational data is critical for insurers to assess the new risk and develop appropriate pricing models.
The institute said insurers need better data access, stronger overseas risk controls and reforms to subsidiary rules as domestic market pressures intensify.
More than 80% of insurers have already met OJK's 2026 requirements, but experts say capital alone will not fix weak fundamentals as tougher 2028 rules loom.
Issued after insurer feedback, the guidance requires appointed actuaries to report to boards and insurers to run validation throughout the first year of adoption.