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Ever Had an Insurance Claim Delayed for Months Without a Clear Reason? You’re Not Alone.
Insurance is meant to be the thing that protects you when something goes wrong. But for many policyholders in Zambia, and for many insurers and brokers trying to stay compliant, the insurance sector itself has become a source of legal uncertainty. Coverage disputes drag on. Claims get delayed. Policy wording gets argued over in ways that feel more like a second disaster than a resolution to the first.
The good news is that Zambia’s insurance industry now operates under one of its most comprehensive legal frameworks yet, and understanding it can save insurers, brokers, and policyholders a great deal of pain.
The Legal Foundation: The Insurance Act, 2021
Zambia’s insurance industry is governed by the Insurance Act, 2021 (Act No. 38 of 2021), which came into force in December 2022 and completely replaced the old Insurance Act of 1997. This wasn’t a minor update. It rebuilt the rules around how insurers, reinsurers, brokers, and agents are licensed, supervised, and held accountable.
The Act is administered by the Pensions and Insurance Authority (PIA), the statutory regulator responsible for overseeing both the pensions and insurance industries in Zambia.
A few of the changes that matter most:
Insurers and reinsurers must now have at least 30% of their shareholding owned by Zambian citizens or citizen-owned companies, with brokers required to meet an even higher threshold of 51% citizen ownership (Section 49 of the Act).
Claim settlement timelines are now regulated, rather than left to an insurer’s discretion (Section 28), which is a meaningful shift for anyone who has waited months for a payout with no clear explanation.
Life insurance premiums now require actuarial approval before they can be charged (Section 48), aimed at making pricing more transparent and less arbitrary.
Licence suspensions and cancellations must now be published publicly (Section 14), giving policyholders more visibility into which insurers are under regulatory pressure.
Where We See Clients Get Tripped Up
Here’s something we’ve noticed consistently, and it’s rarely the headline legal issue that causes the real damage. It’s the fine print.
Most coverage disputes we handle don’t come down to whether something was insured at all. They come down to how a policy defines a term, what an exclusion clause actually excludes, or whether a condition was triggered by something the policyholder didn’t realise mattered. Insurers draft policies carefully, and understandably so, but policyholders often sign without fully appreciating what a particular clause means until they try to claim against it.
Our advice, long before a dispute ever arises: read your policy as if you’re already trying to claim on it. Ask what would happen if the exact scenario you’re worried about occurred. If the answer isn’t obvious from the wording, that’s worth raising with your insurer or broker before you need the cover, not after.
A Realistic Scenario
Consider a small logistics business that takes out a comprehensive policy covering its delivery fleet. A vehicle is damaged in an accident, and the claim is submitted. Weeks pass. The insurer eventually denies the claim, citing a clause requiring the vehicle to have been driven only by “authorised drivers” listed on the policy, and the driver at the time, while a full-time employee, wasn’t formally added to that list.
This is exactly the kind of dispute that plays out regularly in Zambia’s insurance sector: not fraud, not bad faith, just a gap between what a business assumed was covered and what the policy document actually said. Under the new Act’s claims settlement provisions, insurers must now handle such disputes within prescribed timeframes, but that doesn’t remove the underlying problem, which is that the dispute could often have been avoided with clearer policy review at the outset.
Recent Regulatory Developments Worth Knowing
The insurance sector in Zambia has continued to evolve well beyond the 2021 Act itself. The PIA has recently issued new Market Conduct, Microinsurance, and Reinsurance Regulations, reinforcing standards around consumer protection, local capacity utilisation for reinsurance placements, and capital adequacy, part of a broader effort to modernise the sector and align it with international best practice.
Parliament has also been considering the Pension Scheme Regulation (Amendment) Bill, 2026, which proposes changes to the composition of the PIA’s governing Board, a development worth watching for anyone engaging with the regulator on licensing or compliance matters.
Why This Matters for Insurers, Brokers, and Policyholders Alike
If you’re an insurer or reinsurer, compliance with the Act’s shareholding, solvency, actuarial, and reporting requirements isn’t optional, and the PIA has real enforcement powers, including licence suspension and administrative penalties.
If you’re a broker, the Act imposes specific obligations around client premium transmission and separate client accounts (Sections 21 and 22), with real financial consequences for non-compliance.
If you’re a policyholder, understanding your rights around claims settlement timelines and policy interpretation can be the difference between a straightforward payout and a prolonged dispute.
At Mesdames Jane Jere Legal Practitioners, we advise insurers, brokers, and policyholders on policy interpretation and coverage disputes, insurance claims handling, subrogation, insurance regulatory compliance, and professional indemnity disputes, helping clients navigate this framework with clarity and confidence.
For related reading, see our guides on Corporate and Commercial Law and Banking and Finance Law in Zambia, or explore our Insurance Law category for further updates.
This article was prepared by Mesdames Jane Jere Legal Practitioners and reviewed for accuracy against the Insurance Act, 2021.
