public Offshore verified Last Verified: 2026-11-08

Bermuda

Bermuda's captive classes are supervised by the Bermuda Monetary Authority under the Insurance Act 1978. Class 1 is a single-parent general captive writing only the risks of its owners and their affiliates. Class 2 covers multi-owner captives and captives writing no more than 20 percent of net premiums from unrelated risks. Class 3 covers captives writing more than 20 percent, and up to 49 percent, of net premiums from unrelated risks, together with certain third-party writers that are not commercial Class 3A, 3B, or 4 insurers. Class A and Class B are the long-term equivalents of Class 1 and Class 2. The Authority's 2025 annual report gives 2025 register counts of 159 Class 1, 244 Class 2, 180 Class 3, 12 Class A, and 13 Class B insurers, 608 in those captive classes. The 2024 column of the same table is 632 and matches the report's market statistics for the year ended 31 December 2024. Single-parent captives are the Class 1 and Class A counts, 171 in the 2025 column, which is the same pairing the report used for its 31 December 2024 company-type table. Class 3, 180, is the third-party captive category. Class 2 and Class B together are 257 and mix multi-owner captives with captives writing up to 20 percent unrelated premiums, so that pair is not stored as a group-captive count. New captive-class registrations in the 2025 column were 2 Class 1, 5 Class 2, 1 Class 3, 1 Class A, and no Class B, 9 in total. The report does not publish surrenders. Its 2023 captive insight report, published in December 2025, said segregated and incorporated segregated accounts were in excess of 2,000 and that 15 percent of captive-market companies operated as segregated accounts or incorporated segregated accounts companies. That report does not give an exact cell count, and the 2025 annual report does not update it.

Quick Facts

Verified 2026-11-08

Jurisdiction

Offshore

Legislation

Insurance Act 1978, and the Insurance Returns and Solvency Regulations 1980

Tax Environment

The Insurance Act fee schedule does not impose a premium tax. Captive regulatory cost is the Bermuda Monetary Authority licence fee. The Corporate Income Tax Act 2023 charges Bermuda corporate income tax to Bermuda constituent entities of an in-scope multinational group for fiscal years beginning on or after 1 January 2025. The Government of Bermuda describes that regime as its implementation of the OECD Pillar II 15 percent minimum tax for multinational groups with annual revenue of EUR 750 million or more. Captives that are not constituent entities of an in-scope group are outside that tax.

Last Verified

verified 2026-11-08

Financial Requirements

Minimum Capital & Surplus

Structure Type	Minimum Capital
Class 1	Minimum capital and surplus at least equal to the minimum solvency margin, the greater of a premium-based formula and a reserve-based formula, subject to a $120,000 floor.
Class 2	Minimum capital and surplus at least equal to the minimum solvency margin, subject to a $250,000 floor.
Class 3	Minimum capital and surplus at least equal to the minimum solvency margin, subject to a $1,000,000 floor.
Class A	Long-term single-parent captives maintain minimum capital and surplus at least equal to an asset-based formula, subject to a $120,000 floor.
Class B	Long-term multi-owner captives, and long-term captives writing no more than 20 percent of net premiums from unrelated risks, maintain minimum capital and surplus at least equal to an asset-based formula, subject to a $250,000 floor.
General-business segregated accounts and separate accounts	For financial years commencing on or after 1 January 2027, each segregated account or separate account must meet the relevant solvency requirements on a stand-alone basis and must maintain capital and liquidity adequate to the risks it assumes, independently of the company's consolidated position. A segregated accounts company must not make underwriting, reserving, or distribution decisions by reference to the consolidated capital position of the company as a whole. The account is to be fully collateralised, financed up to the contract's full maximum aggregate exposure and held to the benefit of the insured, or fully funded, financed up to the reserve provision. Where the account writes fully collateralised business, the collateral must be contributed on or before the insurance contract's effective date. This guidance does not apply to long-term business. Incorporated segregated accounts are addressed separately.

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Regulatory Framework

Insurance Act 1978, and the Insurance Returns and Solvency Regulations 1980

Applicable Statutes & Regulations

Insurance Act 1978, including section 17 on statutory financial statements and section 18 on statutory financial returns; Insurance Returns and Solvency Regulations 1980, Schedule I (general-business solvency margin) and Schedule II (long-term minimum margin of solvency); Bermuda Monetary Authority Act 1969, Fourth Schedule, for fees effective 1 January 2026; Corporate Income Tax Act 2023; Bermuda Monetary Authority Guidance Note, General Business Insurers with Segregated Accounts and Separate Accounts (September 2026), issued under section 2B of the Insurance Act 1978, for financial years commencing on or after 1 January 2027. It applies to limited-purpose and commercial insurers in the general-business licence classes that maintain segregated accounts under the Segregated Accounts Companies Act 2000 or separate accounts permitted for insurers incorporated under a private act. It does not apply to long-term insurers. Incorporated segregated account companies and incorporated segregated account insurers remain under the separate guidance note issued in December 2020. Where this note and the Special Purpose Insurer guidance note issued on 1 July 2020 do not align, the Special Purpose Insurer note takes precedence for that class. The Authority will consider transitional applications in the first year after implementation. Bermuda Monetary Authority Notice, Agreed Upon Procedures for Segregated Account and Separate Account General Business Insurers (23 September 2026).

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Tax Environment

Detailed Profile

Regulatory & Statistical Profile

bar_chart Captive Market Volume

Reporting Year 2025

Total Active Captives 608

New Captives Licensed 9

Surrendered Licenses Pending verification

pie_chart Structure Distribution

Pure / Single Parent 171

Group / Association Pending verification

Sponsored / Cell Captives Pending verification

Individual Segregated Cells Pending verification

Other Allowed Types 180

checklist Authorized Captive Structures

Class 1 single-parent general captivesClass 2 multi-owner general captives and captives writing up to 20 percent unrelated net premiumsClass 3 captives writing more than 20 percent and up to 49 percent unrelated net premiumsClass A single-parent long-term captivesClass B multi-owner long-term captives and long-term captives writing up to 20 percent unrelated net premiumsSegregated accounts companies and incorporated segregated accounts companies

payments Fees & Solvency Compliance

Year Legislation Passed

1978

Licensing Speed

Pending verification

Premium Tax Rate

No premium tax is imposed by the Insurance Act fee schedule. Bermuda corporate income tax applies only to Bermuda constituent entities of an in-scope multinational group, for fiscal years beginning on or after 1 January 2025. The Government describes the rate as the OECD Pillar II 15 percent minimum for groups with annual revenue of EUR 750 million or more.

Incorporation / Initial Fee

2026 registration fees in the Bermuda Monetary Authority fee schedule, effective 1 January 2026: Class 1 general business $2,250; Class 2 general business $4,375; Class 3 general business $17,800 where expected gross premium does not exceed $5 million, then $19,800, $22,550, $25,920, and $30,000 at the published premium bands; Class A $13,570; Class B $13,570.

Annual Maintenance Fee

2026 annual fees, also effective 1 January 2026, match those registration amounts for Class 1 ($2,250), Class 2 ($4,375), Class 3 ($17,800 to $30,000 by gross premium written), Class A ($13,570), and Class B ($13,570). For a segregated accounts company the premium measure combines the general account and the segregated accounts. Annual fees cancelled by deregistration, discontinuance, or merger before 31 March are pro-rated; otherwise the full annual fee is due.

Annual Filing Requirements

Under section 17 of the Insurance Act 1978, a Class 1, Class 2, or Class 3 insurer that is not also Class C, D, or E, and a Class A or Class B insurer, files statutory financial statements within six months after the financial year-end, or within a longer period of up to nine months that the Authority allows on application. The statutory financial return under section 18 is filed at the same time. A loss-reserve specialist's opinion is required annually for a Class 3 insurer and every third year for a Class 2 insurer. The Act does not state that opinion for a Class 1 insurer. For a general-business insurer with segregated accounts or separate accounts, in a financial year commencing on or after 1 January 2027, the statutory financial statements include a Schedule of Segregated Accounts for the general account and each cell. The Schedule forms part of the annual statutory filing and is outside the scope of the statutory audit. The annual statutory submission includes a Principal Representative attestation, embedded in the Schedule and signed annually, that the Schedule reflects the position of each segregated account and the company's financial standing and that the collateral covers the associated liabilities. Under the Authority's 23 September 2026 agreed-upon procedures notice, the approved auditor performs those procedures and files the report separately from the statutory audit opinion, concurrently with the annual statutory financial return.