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CP11/26 – A tailored regime for captive insurance

AI Analysis

Executive Summary

The PRA has issued Consultation Paper CP11/26 proposing a **tailored prudential regime for UK captive insurance undertakings**, with responses due by 14 October 2026. This matters for compliance teams in insurance groups and large corporates because it will create a distinct authorisation and supervisory framework for captives under Solvency UK, potentially changing capital, governance, and reporting expectations and opening a new strategic option to domicile captives in the UK.

What Changed

  • - The PRA proposes to establish a dedicated UK regulatory regime for captive insurers, separate from the standard Solvency UK treatment for commercial (non‑captive) insurers.
  • Captive insurers would benefit from proportionate prudential requirements (for example simplified capital, reporting, and risk management expectations) reflecting their limited and group-focused risk profile, while still being subject to core solvenc
  • The consultation seeks views on eligibility criteria for captives, likely including ownership (group‑owned), purpose (insuring or reinsuring parent/group risks), and restrictions on third‑party business volumes.
  • PRA proposes a UK authorisation and licensing pathway specifically tailored to captives, with adjusted expectations for business plans, risk appetites, and use of reinsurance and fronting structures.
  • The regime is intended to sit within Solvency UK rather than as a completely separate legislative framework, implying changes to the PRA Rulebook and supervisory statements rather than primary legislation.
  • The paper indicates coordination with the FCA on any conduct‑related implications, especially where captives interact with UK policyholders or markets.

Suggested Considerations

  • Review CP11/26 in detail and perform an internal impact assessment on how the proposed captive regime would affect your group’s current or planned captive insurance structures, including domicile and regulatory capital profile.
  • Identify whether any existing insurance entities within the group may fall within the PRA’s proposed definition of a captive and assess whether reclassification would be beneficial or would trigger additional compliance work.
  • Prepare and submit a coordinated consultation response by 14 October 2026, addressing eligibility criteria, proportionality of capital and reporting requirements, and any operational or tax implications for your captive strategy.
  • Map existing governance, risk management, and internal control frameworks for captives against PRA’s proposed expectations and identify gaps that would need remediation ahead of the regime’s expected go‑live in mid‑2027.
  • Engage with group legal, tax, and treasury teams to evaluate whether onshoring an offshore captive to the UK, or establishing a new UK captive, becomes strategically attractive under the tailored regime, and model scenarios accordingly.
  • Update regulatory change logs and risk registers to include CP11/26 as a material upcoming change for insurance and corporate risk‑financing, with clear ownership assigned in compliance and risk functions.

Key Dates

Summer 2026
– PRA (and FCA) indicated they would consult on a new UK captive insurance regime as part of their 2026 supervisory priorities and joint statements
14 October 2026 DEADLINE
– Deadline for responses to CP11/26 “A tailored regime for captive insurance”
Mid 2027
– Target implementation date for the new UK captive insurance regime, as indicated in prior PRA policy communications and government consultation responses

Compliance Impact

Non‑compliance with the eventual captive regime (for example mis‑classification of entities, inadequate capital or governance relative to PRA expectations) could lead to authorisation issues, supervisory interventions, restrictions on business, or requirements to restructure existing captive arrangements. Given the regime will sit within Solvency UK, failures may also affect group capital position

Who is Affected

UK‑authorised and prospective captive insurance and reinsurance undertakings (including single‑parent and group captives) seeking or holding PRA authorisation.UK‑headquartered corporates and multinationalsExisting UK insurance groupsInsurance intermediaries and structuring advisorsGroup risk, treasury and tax functions

AI-generated analysis. May contain errors or omissions — verify with the original PRA source before acting. Full disclaimer.

Summary

Consultation paper 11/26

Relevant Firm Types

InsuranceBankAll Firms
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