Supervision Rules for Internationally Active Insurance Groups being proposed by BMA
The Bermuda Monetary Authority (BMA) intends to implement new rules under a new Insurance (Internationally Active Group Supervision) Rules 2026 (Proposed Rules) to align Bermuda’s regulatory framework with international standards for Internationally Active Insurance Groups (IAIGs) set by the IAIS (of which Bermuda is a member). An IAIG is an insurance group who, subject to the BMA’s determination, writes premiums in three or more jurisdictions, has gross written premiums outside of Bermuda of at least 10% of the insurance group’s total gross written premiums and on a three-year rolling average it has total assets of at least $50 billion or its total gross written premiums are at least $10 billion. Following the BMAs’ consultation period on the Proposed Rules that closed on 30 September 2026, final rules are expected in Q4 2026.
The purpose of the Proposed Rules is to strengthen oversight of Bermuda-based IAIGs through enhanced governance, risk management, and reporting requirements, and to ensure that IAIGs domiciled in Bermuda (of which there are currently three), and any other groups which may be deemed as such in the future, are subject to clear, enhanced supervisory measures.
Key proposals include:
- Stronger group-wide governance: IAIG heads will be accountable for group-wide governance, risk management, oversight, and reporting material changes to the BMA.
- Enhanced risk management: Groups must maintain comprehensive risk and control frameworks, with annual independent reviews of internal controls.
- Enterprise Risk Management and internal controls (ERM): Robust group-wide ERM frameworks will be required, with independent reviews every three years. Internal controls would require independent review at least annually.
- Intra-group oversight: Significant transactions and risk exposures between affiliated entities must be monitored and reported to the BMA.
- Investment governance: Groups must maintain risk-aligned investment policies and apply enhanced oversight to complex or illiquid investments.
- Liquidity management: Requirements include stress testing, liquidity assessments, contingency funding plans, and supervisory evidence packs.
- Reporting and crisis management: Enhanced reporting will support BMA supervision, and the BMA may coordinate with other regulators on crisis management and recovery planning.
IAIGs and groups likely to fall within the regime should begin assessing their readiness for the new requirements. Appleby’s insurance team is well positioned to assist in this regard, and to guide generally on compliance with the BMA’s regulatory requirements for IAIGs.
