BVI insurance companies, insurance intermediaries and insurance manager licensing guide

The BVI FSC’s Insurance Division prudentially supervises insurance business carried on in or from the BVI and handles licensing of insurance companies, insurance managers, insurance intermediaries (agents and brokers) and loss adjusters. No person may carry on or hold themselves out as carrying on the corresponding business in or from the BVI without a licence. A BVI Business Company is deemed to carry on that business from the BVI even if it conducts the relevant business only outside the BVI.

This page explains insurance companies, insurance managers and insurance intermediaries only. Whether the business also triggers regimes for securities investment, virtual assets, trust companies, or financing and money services must be assessed separately under the corresponding laws. Being regulated by the same FSC does not allow one insurance licence to cover other regulated activities.

• First confirm who underwrites the risk, who provides or arranges insurance for policyholders, and who provides professional insurance management services.
• Confirm again whether the risk concerns domestic business in the BVI and whether the proposed licensee is a BVI company or a foreign insurance company.
• The licence authorizes only the categories, classes of insurance business and conditions specified in the licence; it does not automatically cover additional products or regions.

Section 7 of the Insurance Act divides insurance company licences into Category A to F. Categories A, C, D, E and F may be issued only to a BVI Business Company; Category B may be issued only to a company incorporated, registered or established in a jurisdiction outside the BVI. A Category B applicant must also demonstrate that it is duly authorised in its home jurisdiction, that the proposed business is lawful there and that it is subject to insurance regulation in that jurisdiction.

A Category is not a blanket authorization to underwrite without limits. The licence must specify the permitted classes of insurance business; classes not stated are not authorized. For an application, map the types of policies, premium pricing, claims, reinsurance, asset-liability matching, and solvency arrangements to the proposed classes.

• Category A: BVI Business Company, which may conduct insurance business, including domestic business.
• Category B: A company incorporated outside the BVI may conduct insurance business in the BVI, including domestic business.
• Category C: a BVI Business Company may carry on non-domestic insurance and, if permitted by its licence, non-open-market reinsurance.
• Category D: a BVI Business Company may carry on reinsurance, including open-market reinsurance.
• Category E: BVI Business Company, which may underwrite related party business only.
• Category F: a BVI Business Company primarily conducting related party business and underwriting limited unrelated party business only to the extent necessary to qualify as an insurance company under foreign law.

An insurance manager is a person who provides insurance expertise to an insurer; an insurance intermediary is an insurance agent or broker. Each must apply separately for a licence under section 40 of the Insurance Act, and the applicant must be a BVI Business Company. A loss adjuster is also a separate category under the section 40 framework, but is outside the scope of services on this page.

An insurance intermediary licence may be issued only as an insurance broker or insurance agent. An agent licence must specify the insurer that has appointed or will appoint the agent; if the agent stops representing an insurer, the FSC must be notified in writing within 14 days. A broker may not also act as an agent, whereas an agent licence holder may also act as a broker without obtaining a separate licence.

• Insurance manager: provides professional insurance management services and cannot conduct business with third parties without a licence.
• Insurance broker: represents clients in arranging or negotiating insurance; it must not be described as an insurance agent.
• Insurance agent: Represents the insurer specified on the licence; an application must be made to the FSC to add or remove an insurer.
• Insurance commissions for business conducted in the BVI must not be paid to anyone who does not hold an insurance intermediary licence.

If applying for an insurance company licence in Category A, C, D, E or F, the statutory applicant must be a BVI Business Company in the form of a company limited by shares. An insurance manager and an insurance intermediary must likewise apply as a BVI Business Company. Category B is for a company incorporated outside the BVI that satisfies its home jurisdiction's authorization and regulatory requirements; it cannot be replaced by any BVI shell company.

Every BVI Business Company must continuously maintain a registered office and registered agent in the BVI. The company must also keep or deposit at the registered agent’s office its memorandum and articles, register of members, register of directors and copies of documents filed, and retain records sufficient to explain its transactions and financial position. The registered agent is the company-law statutory contact point; this does not automatically make it the insurance manager, compliance officer or actual manager.

• An application to incorporate a company may be submitted to the Registrar only by the proposed registered agent.
• Company incorporation and FSC insurance authorization are two interconnected but distinct procedures.
• If an SPC structure is proposed, in addition to company formation, review the approval requirements under insurance law for adding a segregated portfolio or cell.

The FSC reviews the fit and proper status of the applicant, directors, senior officers and persons holding significant or controlling interests. Application materials should therefore clearly show direct shareholders, the control chain, ultimate beneficial owners, ownership percentages, source of funds and related-party relationships. Do not misstate company-law BO filing requirements as meaning that the FSC necessarily approves based on one fixed ownership percentage; approvals for significant and controlling interests under insurance law must be assessed separately.

From 2 January 2025, all BVI Business Companies and limited partnerships must file BO information with the Registrar of Corporate Affairs through VIRRGIN. The FSC clarified in 2025 that, even if there has been no change in members, a register of members filed before the 2025 amendment must also be re-filed under section 43A and the transitional provisions. Directors, members and BOs are separate filing transactions in the system.

• A newly established entity should arrange collection of member, director and BO information and VIRRGIN filings upon incorporation; it should not wait until after filing a licence application to gather the information.
• An official example from 2025 shows that a new company that does not submit BO information within 30 days will begin to incur late-filing consequences; the actual case should be assessed against the system rules visible to the registered agent on the filing date and any applicable exemptions.
• If the materials do not include a given name, surname or full date of birth, the system may request supporting documents. Documents must be certified as required by the FSC and submitted in English or with an English translation.

A BVI company must maintain a register of directors. The version of the BVI Business Companies Act available on the FSC website provides that a copy of the register of directors must be filed with the Registrar within 21 days after the first directors are appointed; thereafter, a copy reflecting any change to the register of directors must be filed within 30 days. The 2025 VIRRGIN notice also confirms that directors, members and BO are separate registration transactions.

However, it should not be stated categorically that “directors’ names are fully public.” The public search guidance updated by the FSC in 2025-9 lists the contents of a Search Report as including the company name, number, type, incorporation date, status, registered agent and address, share/capital information and transaction history. It does not list directors’ names as a standard Search Report field. Whether particular director information can be obtained should be determined by reference to transaction records, documents available on request, the company law in force at the time and the search fees paid.

• Filing a register of directors with the Registrar does not mean that all directors’ details are automatically included in a general Search Report.
• Appointments of directors/senior officers of companies and licensees may also trigger FSC prior approval requirements.
• Do not conflate the access rules for director register searches, register of members documents and the BO register.

On 2026 4, 1, the BVI FSC enabled the “Legitimate Interest” transaction and request-for-access functions for BO registers. This is a procedure for requests, objections and appeals concerning beneficial ownership information. It does not mean that all company information is automatically open to any member of the public, and should not be extrapolated into a general public-access regime for registers of directors or members.

After receiving a request, the registered agent has 5 days to submit a notice of objection, followed by a further 5 days to apply to oppose disclosure of BO information. After the Registrar makes a decision, an intention to appeal must be submitted within 3 days, and the formal notice of appeal within a further 21 days. Where there is no objection or opposition, the FSC states that the operational processing period for the transaction is 12 days.

• Have the registered agent maintain a dedicated notification email address to ensure timely receipt of requests and decisions.
• Supporting documents should be PDFs in English or accompanied by English translations; the FSC requires valid KYC documents to be certified.
• Where enforcement, a competent authority, a confidential investigation or an exemption from disclosure is involved, the request should be handled by BVI counsel and the registered agent in accordance with the procedures in force at the time.

Key persons of insurance companies, insurance managers and insurance intermediaries are subject to fit-and-proper review. For insurance managers and insurance intermediaries, a director or officer must not be appointed without the FSC’s prior written approval. If that person leaves office or is no longer employed, the licensee must notify the FSC in writing within 14 days and state the reason. An insurance company applicant must also demonstrate that its directors, officers and persons holding significant/control interests meet the fit-and-proper standard.

The Regulatory Code requires licensees to establish compliance policies and systems, maintain a compliance manual, and appoint a compliance officer approved by the FSC who has appropriate skills and experience and is a fit and proper person, unless a statutory exemption applies. The appointment, independence, availability and AML/CFT responsibilities of the MLRO must also be arranged in accordance with anti-money laundering laws and business risks. The titles CO and MLRO must not be treated as interchangeable, nor should it be assumed that the same person must hold both roles in every case.

• Both insurance managers and insurance intermediaries must continuously appoint an individual who is FSC-approved, fit and proper, and actually resident in the BVI as their designated representative.
• If the representative spends more than 120 days outside the BVI in a given year, they are not regarded in law as actually residing in the BVI.
• Notify the FSC within 14 days after the appointment or termination of a representative; a termination notice must state the reason.
• An insurance intermediary may apply for an FSC exemption from appointing a representative only if it has no more than 3 employees, has expected annual turnover of no more than US$200,000, or its nature, scale and complexity otherwise justify the exemption. The exemption does not take effect automatically, and the general exemption does not apply to insurance managers.

At the time an insurer is licensed, it must have paid-up capital of at least the statutory minimum and maintain capital resources and solvency while operating. The FSC may require more than the minimum depending on risk, business scope and reinsurance arrangements. For captive insurance business, the FSC FAQ lists minimum paid-up capital of US$100,000 for a general-insurance captive and US$200,000 for a long-term insurance captive. These figures are not a complete capital table for all Category A to F, all insurance classes or all risk structures.

The minimum paid-up capital for an insurance manager and insurance intermediary is US$25,000, but the law requires the higher of the statutory minimum and any case-specific direction from the FSC, and financial soundness must be maintained continuously. Both licence holders must also maintain professional indemnity, fidelity guarantee and other insurance arrangements appropriate to their business. US$25,000 must not be understood as a one-time contribution after which liabilities and ongoing capacity to operate can be ignored.

• Minimum paid-up capital is not a substitute for reserves, reinsurance coverage, day-to-day working capital, or any additional capital that the FSC may require.
• Insurance managers and insurance intermediaries must notify the FSC in writing immediately if their capital falls below the amount they are required to maintain.
• Prepare a case-specific capital assessment based on the target licence, insurance class, policy limits, estimated premiums, claims exposure, and reinsurance arrangements.

The following are official US-dollar fees stated in the text of the FSC website’s 2023 year fee regulations. They exclude fees for registered agents, lawyers, audits, actuarial services, compliance personnel, insurance, offices and other professional services. An insurance company’s annual fee depends on its licence category and the prior-year premium basis; a single fixed “Captive annual fee” cannot summarise all insurance companies.

Government incorporation and annual fees at the BVI company level also depend on the company type and the number of authorised shares. For a company limited by shares authorised to issue no more than 50,000 shares, both the incorporation fee and annual fee are US$450; where the number exceeds 50,000 shares, both are US$1,200. Generally, a company incorporated or continued from 1 to 6 pays its annual fee on 31 5 each following year, while a company incorporated or continued from 7 to 12 pays its annual fee on 30 11 each following year.

• Insurance company renewal tiers should be calculated using the definition of “total premiums / total gross premiums in the preceding year” in the fee regulations, not by substituting share capital or asset size.
• FSC application, issuance and renewal fees are separate fee items from BVI company formation, annual fees, register filings and registered agent fees.
• Before filing or renewal, the registered agent should confirm each fee amount and due date against the fee schedule in force on that date.

A BVI registered office and registered agent are ongoing statutory requirements for every BVI Business Company, but they do not automatically demonstrate that an insurance business has sufficient personnel, management, risk controls or practical operating capacity. Application materials should truthfully state where management, claims, actuarial work, underwriting, reinsurance, investment, outsourcing and oversight take place, and align that information with the licensed business plan.

Under the economic substance law, insurance business is a relevant activity, as defined by the Insurance Act. Whether the economic substance test applies, which core income-generating activities must be conducted in the BVI, and whether local personnel, premises, and expenditure are adequate depend on the entity’s actual activities and applicable tax status. There is no fixed employee headcount or “registration means compliance” formula applicable to all insurance licensees.

• Record separately the registered office, location of the designated representative, location of the insurance manager and the actual board/management activities.
• If key functions are outsourced, explain in the business plan the service provider, responsibilities, oversight, data and business continuity arrangements.
• Before implementation, have professional advisers review together the local requirements for insurance permissions, economic substance filings, and the consequences in each shareholder’s tax-residence jurisdiction.

An insurance company application must use an FSC-approved form and include a detailed business plan. The Regulatory Code requires an insurance company’s plan to cover its first 5 operating years; plans for other licensees, such as insurance managers and insurance intermediaries, generally cover the first 3 years. All projections should explain their assumptions, sources of capital and how funds will be made available. Insurance-company projections should also be appropriately stress-tested and must not present only a best-case scenario.

An insurance company business plan should also reflect the classes and types of policies proposed to be written, premium-pricing assumptions, claims and accounting methods, retentions and deductibles, projected solvency margin, reinsurance arrangements and reinsurers, stop-loss or excess-of-loss protection, investment/asset-liability matching, and follow-on funding sources in the event of a capital shortfall. Managers and intermediaries should focus on explaining the services provided, client base, agency authority, personnel, funds, risks, outsourcing and compliance controls.

• Company structure chart, direct shareholders and UBO ownership chain, biographies of directors and senior officers, and Fit and Proper declarations.
• Audited or management accounts, an explanation of start-up capital and its source, and three- or five-year financial projections and stress tests.
• Policies for underwriting, claims, reinsurance, investments, complaints, conflicts of interest, outsourcing, compliance, AML/CFT, sanctions, and business continuity.
• Information and approval pathways for the proposed insurance manager, appointed representative, compliance officer, MLRO, auditor and actuary (where applicable to the business).

A workable process is to classify the business and licence first, then determine the applicant, control chain, key personnel, capital and local arrangements; next, organise the business plan and supporting documents using the approved forms, pay the applicable application fee and submit to the FSC. The FSC will examine whether the applicant and relevant persons meet the Insurance Act, Regulatory Code and fit-and-proper standards, and may request additional material on risks, management, financial resources, reinsurance and the public interest.

Neither the Insurance Act nor the general FSC application pages provide a uniform number of days for determination that can be promised externally for an insurer, insurance manager or insurance intermediary licence. Any project schedule can only estimate preparation and response periods and is affected by document completeness, shareholder and personnel backgrounds, business complexity, FSC inquiries and approval conditions. An estimated timeline must not be presented as a guarantee of approval or a guaranteed licensing date.

• First classify the facts and check for conflicts to avoid changing the underwriting entity, client regions or service role midway through the application.
• Shorten the controllable preparation period through a complete initial submission, traceable sources of funds and a contact person ready to respond to enquiries at any time.
• Commence regulated business only after the FSC has actually issued the licence and all conditions have been satisfied.

For a BVI insurer, the sale, transfer, pledge or other disposal of a significant interest or controlling interest, its direct or indirect acquisition, and any share allotment or capital restructuring that results in the acquisition, increase or reduction of such an interest are, in principle, subject to prior written FSC approval. The application should be made by the insurer, and the FSC will assess whether the person acquiring the interest after the transaction meets the fit and proper standards.

For insurance managers and insurance intermediaries, prior written approval is also required for changes in significant interests or control interests of the same kind. If a change in a licensee’s interests does not reach the significant-interest or control-interest threshold, the FSC must still be notified within 14 days after it occurs. A foreign Category B insurance company must notify the FSC in writing within 14 days after a change in persons with significant or control interests, unless the Regulatory Code applies differently or the FSC adjusts the requirement for the particular case.

• An insurance company must apply for a licence variation or conversion to add or remove a class of insurance business or to change its insurance company category.
• A BVI insurer must obtain the FSC’s prior written approval to establish or operate a branch or representative/liaison office outside the BVI, or to establish, form or acquire a subsidiary.
• Adding or removing an insurance company represented by an insurance agent requires an application to amend the licence under section 46.
• Changes to company-level directors, members, BOs, registered office, memorandum and articles, or shares may also trigger filings with the Registrar.

Category C, D, E and F insurance companies must continuously appoint a company holding an insurance manager licence as their insurance manager and must first obtain the FSC’s written approval for that appointment. This requirement shows that an insurance company and an insurance manager cannot be treated as a single “Category E/F licence”: they are a regulated insurer and a licensed professional service provider in a statutory governance relationship.

The insurer and insurance manager must notify the FSC at least 30 days before termination of the insurance manager’s appointment, unless the FSC agrees to a shorter period. After an appointment or termination, the insurer must also notify the FSC in writing within 14 days. If the existing insurance manager ceases to act, the insurer must lawfully appoint a qualified insurance manager again within 14 days.

• A Category B insurance company incorporated outside the BVI with no staff office in the BVI must maintain an appointed representative in the BVI.
• The representative must be either a person holding an insurance intermediary licence and appointed as its insurance agent, or a person holding an insurance manager licence.
• A foreign insurance company must notify the FSC in writing within 14 days after appointing or terminating a representative; a termination notice must state the reasons.

A relevant insurance licensee must prepare financial statements for each financial year in accordance with the Regulatory Code and applicable accounting standards; the statements must be approved by the board and signed on behalf of all directors by at least one director. Unless an applicable exemption or shorter prescribed period applies, the financial statements and statutory accompanying documents must be submitted to the FSC within 6 months after the end of the financial year; late submission is an offence. The FSC may also require short-period financial statements, returns in an approved form and other information.

In 2024, the FSC issued updated annual return forms for domestic insurers, captive insurers, insurance managers and insurance intermediaries. The notice set the deadline for the 2023 return at 2024 3 31. The latest forms and notices should be checked directly each year; the notice date for one year should not be applied indefinitely. The 2025 annual financial return notice for companies also states that FSC-regulated companies required to file financial statements with the FSC are not subject to the general registered-agent annual financial return requirement under section 96A.

• Keep ongoing records of transactions, financial condition, insurance contracts, claims, reinsurance, board matters and compliance.
• Maintain approved auditors, actuaries and other independent persons as applicable, and promptly address any required approvals or changes.
• Pay BVI company annual fees according to the incorporation/continuation date, and pay annual licence fees by the prescribed dates in accordance with the insurance fee schedule.
• Periodically review capital, reserves, solvency, professional insurance, AML/CFT controls and key personnel/shareholding information.

An Approved Investment Manager is an investment business approval route under the Investment Business (Approved Managers) Regulations. It may manage investments or provide investment advice; it is not a licence for an insurer, insurance manager or insurance intermediary and cannot replace the insurance permissions described on this page. Including Approved Manager in insurance Categories A—F, or treating it as covering underwriting, brokerage, agency or insurance management, is an incorrect classification.

The official Regulations provide that a complete application must be submitted at least 7 days before the intended commencement date of the relevant business, unless the FSC accepts a shorter period in writing. Only where an application is made within that period may the applicant temporarily carry on the relevant business from the date of submission, for a maximum of 30 days; the FSC may extend this by up to a further 30 days. Accordingly, “unlimited operation from the day of submission” is incorrect: temporary status is subject to a complete application, the statutory time limit and the FSC’s decision, and the business must cease immediately if the FSC refuses the application.

• The total assets under management for private or professional funds must not exceed US$400 million or its equivalent in another currency.
• When managing one or more closed-ended funds, the asset management cap is US$1 billion; it is calculated by reference to total capital commitments.
• Notify the FSC within 7 days after exceeding the threshold; ordinarily, restore eligibility or submit an application for a SIBA licence within 3 months, failing which the entity will no longer qualify as an Approved Manager.
• 2023 Fee Regulations: Approved Manager application fee US$1,200; approval fee and annual renewal fee are each US$1,800.

Financing and money services are separate legal regimes and should be analysed independently based on the actual activities, such as transfers, exchange, financing, payments or other activities. This page will not include any category, fee or capital requirement for money services in insurance-company Categories A—F, and will not mischaracterize insurance agents, brokers or managers as licensed money-services activities.

The same group may have multiple regulated entities or business lines, but boundaries for entities, contracts, customers, fund flows, personnel, systems and regulatory reporting should be established separately. If an insurance product includes collection, payment, foreign exchange, financing or digital-asset elements, the facts should first be classified. An insurance licence does not, by itself, confer authority to handle customer funds or conduct money services.

• Insurance: classify in accordance with the Insurance Act and insurance-related regulatory documents.
• Insurance managers/intermediaries: comply with sections 37 to 48A of the Insurance Act and the Regulatory Code.
• Financing and money services: verify on a separate page under the Financing and Money Services Act and the latest official fee information.

This page was prepared by Rengangyongsheng (Hong Kong) Limited and explained by business manager Tang Shangyong (Mr Tang). The website may accordingly assist clients in organizing business facts, preparing document checklists, coordinating with registered agents and following up on application communications. This attribution only describes the content and service positioning; it does not constitute endorsement by the BVI FSC, the BVI Government, an insurer, a tax authority or any audit firm.

Whether an application is accepted, whether further information is requested, whether conditions are imposed and whether approval is granted are all determined independently by the BVI FSC under the law and the materials in the individual case. This website does not invent success stories, approval rates, client numbers, processing times or tax outcomes. If regulations, fee schedules, VIRRGIN functions, annual forms or case facts change, rely on official materials available on the application date and advice from licensed BVI professionals.

• Suitable for: preliminary licence classification, document preparation, review of company and personnel governance, and design of an ongoing compliance calendar.
• Separate professional advice is required for: specific policyholder/client jurisdictions, tax residence, sanctions and AML/CFT cases, acquisition completion, disputes, and BO disclosure applications.
• All important figures are shown in US dollars (US$), and the relevant sections explain the different bases for applications, issuance, renewals, capital, and registration.

The links below facilitate verification of laws, application guidance, and fees. Older documents may remain in official repositories; confirm the latest applicable version before submission.

1. Overview of the BVI FSC Insurance Division ↗
2. Insurance Act, 2008 (FSC official legislation text) ↗
3. Insurance Regulations (regulatory text on the FSC website) ↗
4. Regulatory Code, 2009 (FSC official text) ↗
5. Financial Services Fees Amendment Regulations, 2023 ↗
6. FSC FAQ: Captive Insurance Capital Requirements ↗
7. FSC FAQ: Insurance Intermediary Licence Requirements ↗
8. FSC General Licence Application Guide ↗
9. BVI Business Companies Act (FSC website text) ↗
10. FSC Company Structure and Registered Agent Notes ↗
11. BVI FSC Updates on the Implementation of Beneficial Ownership Reporting (Industry Circular No. 12 of 2025) ↗
12. FSC lawful-interest transactions and commencement of access to the BO register (Industry Circular No. 2026 of 11) ↗
13. FSC updates insurance annual return form (Industry Circular No. 1 of 2024) ↗
14. FSC Notice on the Initial Annual Financial Return Filing for Companies (2025, No. 26) ↗
15. Economic Substance Companies and Limited Partnerships Act ↗
16. Approved Investment Managers Guidelines ↗
17. How to search for BVI FSC registered entities ↗
18. Investment Business (Approved Managers) Regulations, 2012 ↗

Tang Shangyong (Mr Tang)Business Manager · Professional Guidance

Proposed by Rengangyongsheng (Hong Kong) Limited / Update 2026-11-02

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