public Offshore verified Last Verified: 2026-11-05

Guernsey

Guernsey is a leading captive centre and the jurisdiction that pioneered the protected cell company. The Guernsey Financial Services Commission regulates insurers under the Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended, using its own solvency rules rather than the EU Solvency II standard formula. At 31 December 2025 the Commission reported 196 non-cellular captives, after 8 additions and 9 surrenders in 2025. That 196 is not a total of all captives: of cells reported by type of insurer, 126 were classified as captives, after 13 additions and 9 surrenders. Pure/single-parent and group/association captive structures are permitted; the Commission does not publish a numerical breakdown of those types, a captive-only premium total, or a standard licensing time. At 31 December 2025 the international insurance sector comprised 44 PCCs, 222 PCC cells excluding insurance-linked securities, 14 ICCs and 46 ICC cells. Those PCC and ICC totals cover the wider international insurance sector and are not all captives. The same sector statistics also show 223 companies and 549 entities in total. The latest financial totals, for 2024, were £29.70 billion of gross assets, £12.62 billion of net worth and £5.19 billion of premiums written by international insurers as a whole, not by captives alone. Captive (re)insurers are Category 5 licensees. Category 6, including special purpose insurers and insurance-linked securities, is authorised separately and is not necessarily captive business. The capital floor is £100,000 for general business and £250,000 for long-term business, and the captive prescribed capital requirement is calibrated at a 90 percent confidence level over 12 months. Under the Income Tax (Guernsey) Law, 1975, as amended, and States of Guernsey Revenue Service guidance, company income tax is 0 percent on insurance income that is not domestic business and 10 percent on domestic insurance business. Reinsurance is outside the statutory definition of domestic business. Insurance supervision is carried out by the Banking and Insurance Division; the Commission does not publish a separate current headcount for insurance supervision alone. The Commission regulates insurers and does not administer individual captives. Most international insurers are administered by licensed insurance managers: 23 were authorised at 31 December 2025, and named managers are on the regulated-entities register. The Commission can pre-authorise later protected-cell-company cells on a product or class basis once the company and its first cell are approved, most often for fully collateralised special purpose insurer cells. It does not publish a 48-hour licensing standard. This profile was reviewed by the Commission (Shaun Green, 5 November 2026) against its published insurance statistics.

Quick Facts

Verified 2026-11-05
Jurisdiction
Offshore
Legislation
Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended, and the Insurance Business (Solvency) Rules and Guidance, 2021
Tax Environment
Under the Income Tax (Guernsey) Law, 1975, as amended, and States of Guernsey Revenue Service guidance, the standard company rate of income tax is 0 percent. The 10 percent company intermediate rate applies to income from domestic insurance business, insurance intermediary business and insurance manager business. Insurance income that is not domestic business, including reinsurance (which the Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended, excludes from domestic business), is taxed at 0 percent. Income from Guernsey land and buildings is taxed at 20 percent. Insurance is an economic-substance category for accounting periods after 1 January 2019. Revenue Service company-tax guidance does not state a separate premium-tax rate.
Contact
Guernsey Financial Services Commission
info@gfsc.gg
Last Verified
verified 2026-11-05
Financial Requirements

Minimum Capital & Surplus

Structure Type Minimum Capital
Category 5 captive, general business £100,000 capital floor. Paid-up share capital must be at least the capital floor, and minimum shareholders' funds must be at least 75 percent of the capital floor. The minimum capital requirement cannot be below the capital floor. The prescribed capital requirement is set at a 90 percent confidence level over the next 12 months
Category 5 captive, long-term business £250,000 capital floor, with the same paid-up capital, shareholders' funds and 90 percent prescribed-capital tests
Category 5 captive, general and long-term £250,000 capital floor
Protected cell company that does not write retail general insurance The capital floor applies to the PCC as a whole. There is no separate capital floor for each cell or for the core. Each cell and the core has a notional minimum capital requirement calculated as if it were a stand-alone insurer, and the PCC minimum is the sum of those amounts, subject to the capital floor
info

Regulatory Framework

Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended, and the Insurance Business (Solvency) Rules and Guidance, 2021

Applicable Statutes & Regulations

Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended; Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002; Insurance Business (Solvency) Rules and Guidance, 2021, including the 2024 amendment to the retail general-business capital floor; Insurance Business Rules and Guidance, 2021; Companies (Guernsey) Law, 2008 (Commission consent to incorporate a protected cell company or an incorporated cell company); Financial Services Commission (Fees and Administrative Penalties) Regulations, 2025; Income Tax (Guernsey) Law, 1975, as amended (company standard rate 0 percent and intermediate rate 10 percent, per States of Guernsey Revenue Service guidance).

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Tax Environment

Under the Income Tax (Guernsey) Law, 1975, as amended, and States of Guernsey Revenue Service guidance, the standard company rate of income tax is 0 percent. The 10 percent company intermediate rate applies to income from domestic insurance business, insurance intermediary business and insurance manager business. Insurance income that is not domestic business, including reinsurance (which the Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended, excludes from domestic business), is taxed at 0 percent. Income from Guernsey land and buildings is taxed at 20 percent. Insurance is an economic-substance category for accounting periods after 1 January 2019. Revenue Service company-tax guidance does not state a separate premium-tax rate.

Detailed Profile

Regulatory & Statistical Profile

bar_chart Captive Market Volume

Reporting Year 2025
Non-cellular captives 196
New non-cellular captives 8
Non-cellular surrenders 9

pie_chart Structure Distribution

Pure / Single Parent Permitted; separate count not published
Group / Association Permitted; separate count not published
International insurance PCCs and ICCs 44 PCCs, 222 PCC cells excluding ILS, 14 ICCs and 46 ICC cells at 31 December 2025. These totals cover the wider international insurance sector and are not all captives. Of cells reported by type of insurer, 126 were classified as captives.
Captive cells 126 as of 2025
Category 6 / ILS (separate) Not necessarily captive business; no captive count is published

checklist Authorized Captive Structures

Category 5 captive insurers and reinsurers. Pure/single-parent and group/association structures are permitted; a separate count is not publishedProtected cell companies and cells used for captive businessIncorporated cell companies and cells used for captive business

payments Fees & Solvency Compliance

Year Legislation Passed
2002
Licensing Speed
No published standard timeline. PCC cells may be pre-authorised on a product or class basis after the PCC and its first cell are approved; this route is most commonly used for fully collateralised special purpose insurer cells.
Premium Tax Rate
Under the Income Tax (Guernsey) Law, 1975, as amended, and States of Guernsey Revenue Service guidance, company income tax is 0 percent on insurance income that is not domestic business and 10 percent on domestic insurance business. That guidance does not state a separate premium-tax rate.
Incorporation / Initial Fee
Under the Financial Services Commission (Fees and Administrative Penalties) Regulations, 2025, as summarised by the GFSC: Category 5 captive insurer or reinsurer application fee £7,850 for a company, PCC core or ICC core. A Category 5 cell of a PCC or ICC is £2,520. A Category 6 special purpose insurer cell is £110. A pro-rata annual fee is invoiced when the licence is issued.
Annual Maintenance Fee
Due 31 January for licences in effect on 1 January. Category 5 captive insurer or reinsurer, including a PCC core or ICC: £7,850. Category 5 cell: £2,520. Category 6 company: £7,725. Category 6 cell that is not a special purpose insurer: £2,520. Special purpose insurer cell: £110. Dormant cell: £205. Change of general representative: £600. Change of controller: £2,760. Category 6, including special purpose insurers and insurance-linked securities, is a separate licence category and is not necessarily captive business.
Annual Filing Requirements
Licensed insurers must deposit an annual return with the Commission within four months beginning on the close of the financial year (Insurance Business (Bailiwick of Guernsey) Law, 2002, as amended, section 37). The return includes the regulatory solvency assessment. Each insurer must also complete an Own Risk and Solvency Assessment at least annually and submit the resulting Own Solvency Capital Assessment with the annual return. The general representative is responsible for filing. A late return attracts an administrative financial penalty. Licensed insurance managers and insurance intermediaries deposit their annual return within six months of the financial year-end. Guernsey company income tax returns are filed separately with the Revenue Service; the 2025 corporate return is due 30 November 2026.

gavel Regulatory Contact Office

Supervisory Authority
Guernsey Financial Services Commission
https://www.gfsc.gg/industry-sectors/insurance open_in_new
Office Address
Regency Court, Glategny Esplanade, St Peter Port, Guernsey, GY1 3HQ
Regulatory Department Staff
Banking and Insurance Division. No separate current headcount for insurance supervision is published.
Captive Administrator
Licensed insurance managers (23 authorised at 31 December 2025). Named managers are listed on the GFSC regulated-entities register. The Commission is the regulator, not the administrator of individual captives.

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