The new checklist for ‘Completing and Submitting (Re)Insurance Authorisation Applications’ together with the ‘Updated Guidance on Completing and Submitting (Re)Insurance Authorisation Applications’ issued by the Central Bank Ireland (CBI) are both likely to speed up the process for licensing new captives in Ireland.
With the new checklist, the CBI has consolidated its five checklists for the authorisation of insurance companies, including captives, into one document.
“We hope that better familiarity with the new, streamlined authorisation checklist will improve the CBI’s ability to provide quicker authorisations for captives and all insurance undertakings,” Marguerite Sinnott, senior associate at William Fry, told Captive Intelligence.
“Additionally, the streamlined checklist will likely make it easier to identity areas where CBI can apply proportionality to captives, leading to a more efficient process.”
Ireland was an early adopter of direct writing captives in Europe, and experienced swift growth following the inception of its captive regulation, with the first direct writing captive formed in 1989.
Initially the domicile had relatively relaxed capital requirements, facilitating smooth formation for companies interested in establishing a captive in Europe.
Despite its early success, however, the number of new captive formations in Dublin has declined since 2016 with the introduction of Solvency II, a perceived lack of proportionality and a conservative regulatory approach largely influenced by the fallout from the 2008 financial crisis.
Sinnott believes the new checklists are steps in the right direction for the domicile.
“If authorisation timelines for captives are improved, this will make Ireland more attractive as a captive domicile in Europe,” she said.
“This presents a great opportunity and applying more proportionality in the authorisation process for captives will improve that opportunity.”
Sinnott said that speedier authorisations can be achieved as the CBI becomes more familiar with the new, streamlined application process.
In the CBI’s July 2024 ‘Guidance on Completing and Submitting (Re)Insurance Authorisation Applications’, the Bank indicated authorisation timelines ranging from three to six months.
“Ideally, captives would fall on the three-month side of that range, rather than closer to six months,” Sinnott added.
She said it would be helpful for captives, for authorisation purposes as well as for day-to-day management purposes, to have a dedicated captive section on the Central Bank website to refer to.
“This area might highlight relevant legislation, regulation, guidance and provide indications of areas where proportionality might be applied to captives,” Sinnott said.