I’m not sure how feasible this route is.
Were I in the seat of a ministry, I would argue that by excluding all NWOHRs, I’m not discriminating based on birthplace because the NWOHR status is independent of birthplace (NWOHR can basically be born in any country, including Taiwan!) 
Of course, one could argue that a NWOHR is much more likely to have been born abroad, but that might be pushing it…
But yeah - it’s worth a try to submit an article 62 discrimination complaint if anything else fails.
Just sent out an FSC complaint about Cathay.
In this case, I’m also complaining about the exclusion of foreign residents in general.
What’s very interesting is that Cathay actually has different, contradicting definitions of who is available to get this insurance. The exclusion of NWOHRs is only mentioned by support - it’s nowhere to be found on their website. That alone should be considered a breach of regulations.
(Skipping the Chinese original because of post length constraints):
Dear Financial Supervisory Commission,
I am an ROC national without household registration in the Taiwan Area (臺灣地區無戶籍國民) who holds a Taiwan Area Resident Certificate (臺灣地區居留證, TARC) and unified identification number (統一證號, UID). On September 6, 2026, when I attempted to apply for Cathay Century Insurance’s BeSafe “Rental/Borrowed Car Peace-of-Mind Travel” insurance, the system classified my government-issued and validly formatted UID as incorrectly formatted. I could neither submit an application nor enter underwriting. Customer service also said that people without household registration are treated as foreign nationals and that foreign nationals cannot obtain this product. Article 3 of the Immigration Act (入出國及移民法), however, expressly includes NWOHRs within the definition of “national.” By classifying me as a foreign national solely because I lack household registration and use a UID, Cathay departed from my legal status and contradicted its own Insurance Notice condition that the applicant and insured “must both be nationals of this country.”
I complained to Cathay on September 15. Cathay’s September 18 response said that the product “uses a National Identification Card number for identity verification and the insurance application; persons who do not meet the current application method cannot currently obtain this product,” and that it has “no corresponding plan at present” to accept other document formats. The response confirms that Cathay chooses to use a National Identification Card number as the operative access gate, but it did not claim that this restriction was based on any individual risk assessment or actuarial or statistical data. Cathay previously insured my own car using the same UID. After this refusal, I also obtained similar domestic rental-car insurance fully online from another provider using the same number. This shows that accepting only National Identification Card numbers is neither a general legal requirement nor a technical necessity for this type of online insurance application, but an undisclosed system-access restriction that Cathay has chosen to maintain. The gate excludes NWOHRs and lawfully resident foreign nationals who hold resident certificates and use UIDs before underwriting begins.
The public disclosures are also inconsistent. The BeSafe product page’s “Applicants and conditions” display lists only personal application, one-hour advance timing and an age restriction. A separately opened Insurance Notice alone states the “nationals of this country” condition described above. The 12-page policy wording titled “Cathay Non-Life Insurance Go-Out Driver-of-Another’s-Car Liability Insurance” (`國泰產物享出門駕駛他人汽車責任保險`), linked from the product page and amended on August 30, 2024, states no qualification based on nationality, household registration or identifier type. Only Cathay’s complaint response confirms that possession of a National Identification Card number is actually required.
These practices may be inconsistent with rules governing insurance underwriting, product review, disclosure and fair customer treatment. Article 7(1)(11) of the Regulations Governing Business Solicitation, Policy Underwriting and Claim Adjusting of Insurance Enterprises (保險業招攬及核保理賠辦法) requires risk assessment and premiums to rest on actuarial and statistical data and prohibits unfair treatment of particular underwriting subjects. Points 11(3) and 37 of the Directions for Review of Non-Life Insurance Products (財產保險商品審查應注意事項) also require refusal to rest on underwriting grounds and special eligibility restrictions to be stated in the policy terms. Articles 8 and 12 of the Financial Consumer Protection Act (金融消費者保護法) require truthful information without concealment or misleading conduct and incorporation of the relevant requirements into internal controls. The Principles for Financial Service Industries to Treat Clients Fairly (金融服務業公平待客原則) further require fair customer treatment throughout product design, sales, service and complaint handling. In addition, Article 62 of the Immigration Act prohibits discrimination on grounds including nationality against people residing in the Taiwan Area and is relevant legal context when assessing the differential treatment in this case.
I therefore ask the FSC Insurance Bureau to exercise its supervisory authority and examine the following:
- Examine whether Cathay’s blanket pre-underwriting exclusion of NWOHRs and lawfully resident foreign nationals who hold resident certificates and use UIDs complies with the rules governing underwriting, the prohibition of unfair differential treatment and fair customer treatment. If Cathay cannot establish with relevant actuarial and statistical data that this blanket exclusion has an objective and reasonable underwriting-risk basis, order correction within a specified period so that both resident groups can submit applications and receive ordinary underwriting. Please also consider the findings in the relevant fair-treatment supervision and evaluation.
- Examine whether the inconsistent eligibility standards presented by the product page, Insurance Notice, policy terms, application system and complaint response comply with disclosure and internal-control requirements. Order Cathay, within a specified period, to apply one consistent and truthful eligibility standard. Any special restriction that is lawfully retained should be disclosed clearly before the consumer applies and stated expressly in the policy terms.
Please inform me of the FSC’s supervisory assessment and handling result for both matters. If correction is ordered, please also state the correction period and how implementation will be confirmed. If the FSC considers any part to fall outside its financial-supervision authority, please explain the reason specifically and identify the competent authority. Thank you for examining and responding to this matter.
