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public Onshore (EU) verified Last Verified: 2026-11-02

Luxembourg

Luxembourg authorises captive insurance undertakings and captive reinsurance undertakings under the Law of 7 December 2015 on the insurance sector, as amended, and the Commissariat aux Assurances supervises them. The Law of 21 July 2021 moved the grant and withdrawal of authorisation from the Minister to the CAA. A reinsurance undertaking must be effectively run by at least one natural-person reinsurance executive, or by a CAA-authorised reinsurance management company represented by such an executive. In CAA Regulation 15/03, consolidated at 27 January 2023, the absolute floor of the minimum capital requirement is EUR 1,300,000 for a captive reinsurer and EUR 3,900,000 for any other reinsurer. Captive insurers use the ordinary insurance floors: EUR 2,700,000 for non-life, EUR 4,000,000 where liability classes 10 to 15 are covered, and EUR 4,000,000 for life. At 1 July 2026 the CAA reported 207 Luxembourg-law reinsurance undertakings and a total staff of 93. It does not publish a captive-only census or a captive-unit headcount. It described 12 new reinsurance authorisations in 2025 and 3 in the first half of 2026 as confirming renewed interest in reinsurance captives. Corporate income tax, in the income-tax law in force at 1 January 2026, is 14 percent up to EUR 175,000 of taxable income and 16 percent above EUR 200,000.

Quick Facts

Verified 2026-11-02
Jurisdiction
Onshore (EU)
Legislation
Law of 7 December 2015 on the insurance sector, as amended (consolidated text as of 3 April 2026), and Commissariat aux Assurances Regulation No. 15/03 of 7 December 2015, as amended
Tax Environment
Captive insurers and reinsurers are taxed as companies. Article 174 of the amended Law of 4 December 1967, in the Administration des contributions directes coordinated text in force at 1 January 2026, sets corporate income tax at 14 percent where taxable income does not exceed EUR 175,000, at EUR 24,500 plus 30 percent of the income above EUR 175,000 where taxable income is between EUR 175,000 and EUR 200,001, and at 16 percent above EUR 200,000. Guichet.lu, updated 7 April 2026, states that a further 7 percent of the corporate income tax is charged for the employment fund. The rate table on that Guichet page still describes the 2019 schedule of 15 and 17 percent and was not used for the rates above. Article 167 allows deduction of technical-provision allocations by insurance and reinsurance undertakings to the extent they correspond to obligations owed to insureds at the year-end, on conditions set by grand-ducal regulation. Every reinsurance undertaking must also constitute a provision pour fluctuation de sinistralité under the Grand-Ducal Regulation of 5 December 2007, as amended. The texts reviewed do not state, as a captive-specific rule, that this fluctuation provision is deductible in full. Municipal business tax and net wealth tax also apply; commune rates and the net-wealth tariff were not verified here. No premium-tax rate was found in the 2015 insurance-sector law materials reviewed.
Contact
Commissariat aux Assurances
caa@caa.lu
Last Verified
verified 2026-11-02
Financial Requirements

Minimum Capital & Surplus

Structure Type Minimum Capital
Captive reinsurance undertaking Absolute floor of the minimum capital requirement EUR 1,300,000 (CAA Regulation 15/03, Article 52(2)(c), consolidation of 27 January 2023)
Other reinsurance undertaking Absolute floor EUR 3,900,000 (Article 52(2)(c))
Non-life insurance, including a captive insurer Absolute floor EUR 2,700,000, or EUR 4,000,000 where any risk in classes 10 to 15 of Annex I, Part A, of the 2015 law is covered (Article 52(2)(a))
Life insurance, including a captive insurer Absolute floor EUR 4,000,000 (Article 52(2)(b))
MCR relative to the SCR The minimum capital requirement must not fall below 25 percent, and must not exceed 45 percent, of the solvency capital requirement including any capital add-on (Article 52(3)). It is calculated at least quarterly
info

Regulatory Framework

Law of 7 December 2015 on the insurance sector, as amended (consolidated text as of 3 April 2026), and Commissariat aux Assurances Regulation No. 15/03 of 7 December 2015, as amended

Applicable Statutes & Regulations

Law of 7 December 2015 on the insurance sector, as amended, including the definitions of captive insurance undertaking and captive reinsurance undertaking and Article 112 on the minimum capital requirement (CAA English consolidation as of 3 April 2026); Law of 21 July 2021, which transferred authorisation from the Minister to the CAA; CAA Regulation No. 15/03 of 7 December 2015 on insurance and reinsurance undertakings, as amended (English consolidation as of 27 January 2023, Article 52); Grand-Ducal Regulation of 5 December 2007 on the authorisation and exercise of reinsurance undertakings, as amended, on the provision pour fluctuation de sinistralité; CAA Circular 22/10 on annual reinsurance reporting; Grand-Ducal Regulation of 28 April 2014, as amended by the Grand-Ducal Regulation of 19 December 2020, on contributions to CAA staff and operating costs; amended Law of 4 December 1967 on income tax, Articles 167 and 174 (coordinated text in force at 1 January 2026).

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Tax Environment

Captive insurers and reinsurers are taxed as companies. Article 174 of the amended Law of 4 December 1967, in the Administration des contributions directes coordinated text in force at 1 January 2026, sets corporate income tax at 14 percent where taxable income does not exceed EUR 175,000, at EUR 24,500 plus 30 percent of the income above EUR 175,000 where taxable income is between EUR 175,000 and EUR 200,001, and at 16 percent above EUR 200,000. Guichet.lu, updated 7 April 2026, states that a further 7 percent of the corporate income tax is charged for the employment fund. The rate table on that Guichet page still describes the 2019 schedule of 15 and 17 percent and was not used for the rates above. Article 167 allows deduction of technical-provision allocations by insurance and reinsurance undertakings to the extent they correspond to obligations owed to insureds at the year-end, on conditions set by grand-ducal regulation. Every reinsurance undertaking must also constitute a provision pour fluctuation de sinistralité under the Grand-Ducal Regulation of 5 December 2007, as amended. The texts reviewed do not state, as a captive-specific rule, that this fluctuation provision is deductible in full. Municipal business tax and net wealth tax also apply; commune rates and the net-wealth tariff were not verified here. No premium-tax rate was found in the 2015 insurance-sector law materials reviewed.

Detailed Profile

Regulatory & Statistical Profile

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Statistical profile pending verification for this domicile.

checklist Authorized Captive Structures

Captive insurance undertakingsCaptive reinsurance undertakings

payments Fees & Solvency Compliance

Year Legislation Passed
2015
Licensing Speed
No published standard authorisation timeline. The CAA examines the financial and organisational conditions, including human resources, before it grants an authorisation.
Premium Tax Rate
No premium-tax rate is set in the Law of 7 December 2015 materials reviewed. Corporate income tax applies under Article 174 of the income-tax law, at 14 percent up to EUR 175,000 of taxable income and 16 percent above EUR 200,000, plus the 7 percent employment-fund charge stated by Guichet.lu.
Incorporation / Initial Fee
No fixed captive application fee is stated on the CAA laws or regulations pages reviewed. The CAA annual report for 2025-2026 says staff and operating costs, other than retired-staff pensions, are met by taxes paid by supervised undertakings and by a state grant. Those taxes are set by the Grand-Ducal Regulation of 28 April 2014, as amended by the Grand-Ducal Regulation of 19 December 2020. The euro schedule in that regulation was not extracted in this verification.
Annual Maintenance Fee
Annual contributions to CAA staff and operating costs are set by the Grand-Ducal Regulation of 28 April 2014, as amended on 19 December 2020. A current euro amount for a captive or reinsurance undertaking was not extracted from that regulation.
Annual Filing Requirements
Insurance and reinsurance undertakings calculate the minimum capital requirement at least quarterly and report it to the CAA (Regulation 15/03, Article 52(4)). Reinsurance undertakings file an annual report. Circular 22/10 requires the claims-fluctuation-provision ceiling table, and the components of the annual movement where the provision exceeds 30 percent of the theoretical maximum. The 2025-2026 annual report says Circular 24/3, as modified by Circulars 25/5 and 25/6, splits the statutory auditor's separate report for reinsurance undertakings into a distinct report and a complementary distinct report, with different submission dates. Those day-counts were not extracted from the circulars. A change in ownership of a captive insurer or a reinsurance undertaking is notified on the forms introduced by Circular 24/9.

gavel Regulatory Contact Office

Supervisory Authority
Commissariat aux Assurances
https://www.caa.lu/en/documentation/laws open_in_new
Office Address
11, rue Robert Stumper, L-2557 Luxembourg
Regulatory Department Staff
93 FTEs
Captive Administrator
Commissariat aux Assurances
caa@caa.lu
Phone: +352 22 69 11-1
Fax: +352 22 69 10
Official Regulatory Sources
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