Cross-sector Reference Checking Arrangement (Phase 3A): A Practical Guide for Banks and Insurers

Published: 18 August 2026  |  Last Updated: 18 August 2026

At a Glance

1. Background: How the Two Schemes Developed

Phase 3A builds on machinery already used by both sectors. For broader financial-sector screening context, see Financial Background Screening in Asia and HKMA & SFC Fit and Proper Guide.

2. Scoping Framework

Phase 3A does not apply to every applicant joining a bank or insurer. The arrangement applies to all authorized institutions and insurance entities, but whether a particular hire triggers an obligation depends on the entity, the role and the candidate’s history.

Entity Scope

Relevant AIs (banking): Authorized institutions under the Banking Ordinance that are also licensed insurance agencies under the Insurance Ordinance to carry on long term insurance business. Insurance entities: Authorized insurers, licensed insurance agencies other than AIs, and licensed insurance broker companies carrying on long term insurance business.

Individual Scope

Phase 3A is engaged when recruiting individuals who will carry on regulated activities in long term insurance business.

3. Trigger Conditions and the Seven-Year Lookback

Before initiating a cross-sector reference check, the recruiting entity should first determine whether the Phase 3A trigger conditions are met. This requires looking at both the role the individual is being appointed to and the individual’s relevant history within the preceding seven years.

When Is a Cross-sector Check Triggered?

A cross-sector check is required where both of the following conditions apply:

• The recruiting entity intends to appoint the individual to carry on long term insurance business; and
• The individual is currently, or was within the previous seven years, appointed by an entity in the counterpart sector to carry on long term insurance business.

In practical terms, Phase 3A is designed to capture movements of in-scope long term insurance intermediaries between the banking and insurance sectors.

What Does the Seven-Year Lookback Mean?

The reference checking framework considers prescribed conduct-related information covering the seven years preceding the application. The recruiting entity should therefore review whether the candidate has relevant counterpart-sector appointment history during that period. If the candidate has no relevant counterpart-sector history within the seven-year window, the cross-sector arrangement under Phase 3A is not triggered. However, this does not necessarily mean that no reference check is required. The recruiting entity’s existing Banking MRC Scheme or Insurance RC Scheme requirements may still apply depending on the role and circumstances.

How Phase 3A Fits with the Existing Schemes

Phase 3A does not replace the Banking Mandatory Reference Checking (MRC) Scheme or the Insurance Reference Checking (RC) Scheme. Instead, it creates a mechanism for the two existing schemes to work together when an in-scope individual moves between the banking and insurance sectors. The key principle is that the recruiting entity continues to follow the procedural requirements of its own sector’s scheme, while using the counterpart sector’s reference template when making the request. Accordingly, there is no separate Phase 3A or “cross-sector” reference checking form. The applicable Banking MRC or Insurance RC template is used depending on which sector is providing the reference.

4. Applying the Correct Framework: Rules vs. Templates

This is one of the most operationally important aspects of Phase 3A. The recruiting entity follows its own sector’s procedural rules, but uses the reference-providing sector’s template. Easy way to remember: follow your own scheme’s rules, and ask on their scheme’s form.

5. Worked Examples

6. Practical Recruitment Workflow

A structured workflow can also be integrated with role-based screening and wider Asia background screening processes.

7. Governance and Supervisory Expectations

Authorized institutions and insurance entities are expected to establish the internal controls, policies and procedures required for smooth implementation. In practice, this means documented procedures, a named contact point for inbound requests, defined escalation paths for late responses and an auditable record of each check. Repeated or systematic failure may indicate weaknesses in corporate governance or internal controls and may prompt supervisory follow-up.

8. Common Misconceptions

For broader hiring controls, see Employment Verification Across Asia, Background Screening Vendor Questions in Asia and In-House vs Outsourced Screening in Asia.

Frequently Asked Questions

9. Looking Ahead: Phase 3B

The regulators will conduct a post-implementation review at the end of 2026. Industry feedback and Phase 3A implementation experience will inform the refinement and expansion of the arrangement. The stated common goal for Phase 3B is to extend cross-sector reference checking to all authorized institutions and insurance entities, covering remaining individuals already subject to the Banking MRC Scheme and Insurance RC Scheme who are not captured by Phase 3A. The precise scope and timing will follow the review.

10. How eeCheck Supports Implementation

eeCheck supports financial institutions across Hong Kong and the wider Asia-Pacific region with compliant, scalable background screening and regulatory hiring workflows.