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Insurance & Risk Transfer across borders
Insurance for operations, assets, deals and people abroad. Led by a WONE Global Partner where one is named. Elsewhere, WONE Global confirms on request whether a vetted Associate firm can act.
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Professional knowledge centre
Insurance & Risk Transfer: how it works
Insurance and risk transfer decides which losses a group keeps and which it passes to insurers, and in every market part of that choice is made by law. Employers' liability, workers' accident cover, motor liability, health insurance for staff and some professional indemnity cover are compulsory, often from the first day of employment. Many countries also restrict where risks may be insured: the UAE requires risks in the State to be placed with licensed insurers, Germany requires non-EU insurers to be authorised, and the US routes non-admitted cover through the insured's home state. Recent changes include the UAE's Federal Decree-Law No. 6 of 2025, in force from 16 September 2025, and the EU's 2025 Solvency II amendments, which give captives lighter treatment.
Source-checked research100% of statements checked against a source49 checked against an official source10 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed
Overview
A group expanding abroad usually wants one global insurance programme bought centrally. That works only if each country allows cover to be provided by the global insurer. Where local placement is required, the usual structure is a locally licensed fronting insurer that issues the policy and reinsures the risk to the global insurer or the group's captive. Compulsory covers must normally be bought locally from authorised insurers or, in Germany, are provided through statutory accident insurance institutions rather than the private market.
The modules below cover the compulsory insurances a new subsidiary must arrange, the rules on placing cover with insurers outside the country, captives, directors' and officers' cover, trade credit and political risk insurance, and the regulators and protection schemes that stand behind policyholders. Points that could not be confirmed on an official page are listed as gaps, notably India, France, US state workers' compensation, MIGA and several captive domiciles.
Compulsory business insurance
Every main market makes some insurance compulsory for employers and vehicle users, and some professions must hold professional indemnity cover. The forms differ: the UK requires private employers' liability insurance, Germany covers employees through statutory accident insurance funded by employers, Singapore requires work injury and foreign worker medical insurance, and Saudi Arabia ties employer healthcare duties to the Cooperative Health Insurance Law.
Sources for this topic · 11
- GOV.UK — Employers' liability insuranceChecked against an official source · checked 2026-10-19 · 3 statements
- The National Archives (legislation.gov.uk) — Road Traffic Act 1988, section 143Checked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Sozialgesetzbuch (SGB) Siebtes Buch (VII), § 2 Versicherung kraft GesetzesChecked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Sozialgesetzbuch (SGB) Siebtes Buch (VII), § 150 BeitragspflichtigeChecked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Pflichtversicherungsgesetz (PflVG), § 1Checked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Bundesrechtsanwaltsordnung (BRAO), § 51 BerufshaftpflichtversicherungChecked against an official source · checked 2026-10-19 · 1 statement
- Ministry of Manpower (MOM) — Work injury compensation insuranceChecked against an official source · checked 2026-10-19 · 2 statements
- Ministry of Manpower — Medical insurance requirements for migrant workersChecked against an official source · checked 2026-10-19 · 1 statement
- Ministry of Human Resources and Social Development — Labor Law, Part Eight: Prevention of occupational hazards, work injuries, and health and social servicesChecked against an official source · checked 2026-10-19 · 1 statement
- Ministry of Human Resources and Social Development — Labor Law, Part EightChecked against an official source · checked 2026-10-19 · 1 statement
- PwC Worldwide Tax Summaries — Saudi Arabia: Corporate - Other taxesChecked against a secondary source · checked 2026-10-19 · 1 statement
Questions on this topic
14 statements on compulsory business insurance
Non-admitted insurance and local placement rules
Whether a group can insure a foreign subsidiary under its global programme depends on local placement rules. The UK prohibits unauthorised insurance business, the UAE requires risks in the State to be insured with UAE-licensed insurers except where cover is unavailable, Germany allows EU insurers to passport in but requires non-EU insurers to be authorised, and the US leaves non-admitted placement to the insured's home state.
Sources for this topic · 8
- The National Archives (legislation.gov.uk) — Financial Services and Markets Act 2000, section 19Checked against an official source · checked 2026-10-19 · 1 statement
- Central Bank of the UAE (Rulebook) — Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance BusinessChecked against an official source · checked 2026-10-19 · 4 statements
- US Department of State — 2025 Investment Climate Statements: United Arab EmiratesChecked against a secondary source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Versicherungsaufsichtsgesetz (VAG), § 61Checked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Versicherungsaufsichtsgesetz (VAG), § 67Checked against an official source · checked 2026-10-19 · 1 statement
- Legal Information Institute, Cornell Law School (US Code reproduction) — 15 U.S. Code § 8201 - Reporting, payment, and allocation of premium taxesChecked against a secondary source · checked 2026-10-19 · 1 statement
- Legal Information Institute, Cornell Law School (US Code reproduction) — 15 U.S. Code § 8202 - Regulation of nonadmitted insurance by insured’s home StateChecked against a secondary source · checked 2026-10-19 · 1 statement
- Monetary Authority of Singapore — Insurance (regulation overview)Checked against an official source · checked 2026-10-19 · 1 statement
Questions on this topic
11 statements on non-admitted insurance and local placement rules
Captives
A captive is an insurer owned by the group to insure or reinsure the group's own risks. It can lower cost and give access to reinsurance markets, but it must sit in a domicile with a suitable regulator and usually works alongside local fronting insurers. The EU's 2025 Solvency II amendments recognise captives' distinct risk profile, US tax rules give small captives a special election, and the DIFC actively hosts captives.
Sources for this topic · 6
- Publications Office of the EU (EUR-Lex) — Directive (EU) 2025/2 amending Directive 2009/138/ECChecked against an official source · checked 2026-10-19 · 3 statements
- Legal Information Institute, Cornell Law School (US Code reproduction) — 26 U.S. Code § 831 - Tax on insurance companies other than life insurance companiesChecked against a secondary source · checked 2026-10-19 · 1 statement
- Legal Information Institute, Cornell Law School (US Code reproduction) — 26 U.S. Code § 831Checked against a secondary source · checked 2026-10-19 · 1 statement
- Dubai International Financial Centre — Insurance, reinsurance and captivesChecked against an official source · checked 2026-10-19 · 1 statement
- Dubai International Financial Centre — Insurance, reinsurance and captives; Financial firmsChecked against an official source · checked 2026-10-19 · 1 statement
- PwC Worldwide Tax Summaries — Guernsey: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-19 · 1 statement
Questions on this topic
8 statements on captives
Directors' and officers' cover
Directors of foreign subsidiaries take personal legal risk under local law, and D&O insurance is the main protection. UK law voids exemptions and most company indemnities for directors but expressly allows the company to buy insurance for them. Germany requires a minimum deductible in D&O policies for AG management board members, and GmbH managing directors face joint and several liability.
Sources for this topic · 5
- The National Archives (legislation.gov.uk) — Companies Act 2006, section 232Checked against an official source · checked 2026-10-19 · 2 statements
- The National Archives (legislation.gov.uk) — Companies Act 2006, section 233Checked against an official source · checked 2026-10-19 · 1 statement
- The National Archives (legislation.gov.uk) — Companies Act 2006, section 234Checked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Aktiengesetz (AktG), § 93 Sorgfaltspflicht und Verantwortlichkeit der VorstandsmitgliederChecked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — GmbH-Gesetz (GmbHG), § 43 Haftung der GeschäftsführerChecked against an official source · checked 2026-10-19 · 2 statements
Questions on this topic
7 statements on directors' and officers' cover
Trade credit and political risk
Trade credit insurance protects exporters and sellers against customers failing to pay, and political risk cover protects against government action, war and currency transfer problems. Private insurers provide most cover, while government export credit agencies such as UK Export Finance and the US Export-Import Bank fill gaps, within international disciplines negotiated at the OECD.
Sources for this topic · 5
- UK Export Finance (GOV.UK) — Export insurance policyChecked against an official source · checked 2026-10-19 · 3 statements
- International Trade Administration (trade.gov) — Trade Finance Guide: Export Credit InsuranceChecked against an official source · checked 2026-10-19 · 3 statements
- International Trade Administration (trade.gov) — Trade Finance GuideChecked against an official source · checked 2026-10-19 · 1 statement
- OECD — Export creditsChecked against an official source · checked 2026-10-19 · 1 statement
- US Department of State — 2025 Investment Climate Statements: United Arab EmiratesChecked against an official source · checked 2026-10-19 · 1 statement
Questions on this topic
9 statements on trade credit and political risk
Regulators and policyholder protection
Knowing who regulates insurers, and what happens if one fails, helps a business choose carriers and handle complaints. The UK splits prudential and conduct regulation and backs policyholders through the FSCS, Germany's BaFin supervises insurers under the VAG, the UAE Central Bank regulates onshore insurance under a 2025 decree-law, and the US regulates insurance state by state.
Sources for this topic · 8
- Bank of England — Prudential regulationChecked against an official source · checked 2026-10-19 · 1 statement
- Financial Services Compensation Scheme — InsuranceChecked against an official source · checked 2026-10-19 · 3 statements
- Federal Ministry of Justice (gesetze-im-internet.de) — Versicherungsaufsichtsgesetz (VAG), § 320Checked against an official source · checked 2026-10-19 · 1 statement
- Federal Ministry of Justice (gesetze-im-internet.de) — Versicherungsaufsichtsgesetz (VAG), § 8Checked against an official source · checked 2026-10-19 · 1 statement
- CBUAE Rulebook — Federal Decree-Law No. (6) of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance BusinessChecked against an official source · checked 2026-10-19 · 1 statement
- US Department of State — 2025 Investment Climate Statements: United Arab EmiratesChecked against a secondary source · checked 2026-10-19 · 1 statement
- Legal Information Institute, Cornell Law School (US Code reproduction) — 15 U.S. Code § 1012Checked against a secondary source · checked 2026-10-19 · 1 statement
- Fox Mandal & Associates — FEMA rules amended for insurance sector FDIChecked against a secondary source · checked 2026-10-18 · 1 statement
Questions on this topic
10 statements on regulators and policyholder protection
Worked example, from official sources
Insurance a new subsidiary must arrange on day one in the UK, Germany, Saudi Arabia and Singapore
A group is opening an office subsidiary with ten employees in each of the UK, Germany, Saudi Arabia and Singapore. Which insurance or insurance-type contributions are compulsory from the start, and what are the key figures?
Assumptions
- Each subsidiary is an ordinary private company with ten office employees from day one; in Singapore four are non-manual staff earning S$2,600 a month or less and two are Work Permit holders; in Saudi Arabia six are non-Saudi.
- Each subsidiary leases one company car.
- No regulated profession or licensed financial activity is carried on.
- Figures are the minimums stated in the sources; premiums are not estimated.
| Market | Employee cover | Key figure | Vehicle | Official source |
|---|---|---|---|---|
| United Kingdom | Employers' liability insurance from an authorised insurer | At least £5 million; £2,500 a day fine if uninsured; £1,000 for certificate failures | Motor insurance required (s143 RTA 1988) | GOV.UK; legislation.gov.uk |
| Germany | Statutory accident insurance (employees insured by law) | Contributions paid by the employer | Keeper's motor liability insurance (PflVG § 1) | gesetze-im-internet.de |
| Saudi Arabia | Occupational hazards social insurance; employer healthcare under the Cooperative Health Insurance Law | 2% of salary for non-Saudi employees (PwC); Saudi employees 21.5% total social insurance | Not confirmed | HRSD Labor Law; PwC |
| Singapore | Work injury compensation insurance; medical insurance for Work Permit holders | WICA for the four covered staff; at least S$60,000 a year per Work Permit holder | Not confirmed | Ministry of Manpower |
Step by step
- United Kingdom: from the day the first employee starts, buy employers' liability insurance of at least £5 million from an authorised insurer and make the certificate available to staff. Insure the company car under the Road Traffic Act.11123
- Germany: employees are insured by law under statutory accident insurance, and the employer owes the contributions, so the subsidiary must register with the competent accident insurance institution rather than buy private employers' liability cover. The vehicle keeper must hold motor liability insurance.456
- Saudi Arabia: register for social insurance and pay occupational hazards contributions, 2% for non-Saudi employees according to PwC; provide healthcare to all workers in line with the Cooperative Health Insurance Law. Where the establishment is outside the occupational hazards branch, the employer bears injured workers' treatment costs.7812
- Singapore: buy WICA cover from a designated insurer for the four non-manual employees earning S$2,600 or less (and any manual workers), and medical insurance of at least S$60,000 a year for each of the two Work Permit holders before their permits are issued.910
- Across all four: buy the policies from insurers licensed or authorised locally; a parent's global policy does not replace these compulsory covers.1314
Conditions that apply
- UK exemptions apply only in narrow cases, such as employing only certain family members or only staff based outside Great Britain.11
- Singapore WICA is optional for non-manual staff earning over S$2,600, but the employer must still compensate valid claims.9
- Failure to insure in Singapore is an offence with fines of up to S$10,000, imprisonment of up to 12 months, or both.15
Result on these facts
The UK and Singapore require private insurance bought from approved insurers from the first day, with clear minimums of £5 million and S$60,000 per Work Permit holder. Germany handles workplace injury through employer-funded statutory accident insurance, so the day-one task is registration and contributions rather than a policy. Saudi Arabia combines social insurance contributions with an employer healthcare duty tied to cooperative health insurance. All four need motor cover where vehicles are used, confirmed here for the UK and Germany.
Confirm the German accident insurance registration deadline, Saudi health insurance minimum benefits and the current GOSI rates for new employees, Singapore S Pass medical insurance rules, and motor insurance minimums in each country. Sector-specific compulsory covers, such as professional indemnity for regulated professions, are not included.
Sources for the worked example
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Most employers must hold employers' liability insurance from an authorised insurer covering at least £5 million, and can be fined £2,500 for every day they are not properly insured. The GOV.UK page covers England, Scotland and Wales; some employers are exempt. Northern Ireland rules were not checked.
Reused from gb-risk-009.
A UK employer must make its employers' liability insurance certificate available to employees and show it to inspectors on request, and can be fined £1,000 for failing to do so. England, Scotland and Wales.
A person must not use a motor vehicle on a road or other public place in Great Britain unless a policy of insurance or security meeting the Road Traffic Act requirements is in force. Road Traffic Act 1988 s143(1)(a), in the Part headed compulsory insurance or security against third-party risks; applies to company vehicles.
In Germany, employees are insured by law under the statutory accident insurance scheme. Section 2(1) no. 1 SGB VII. Cover is provided by the statutory accident insurance institutions (Berufsgenossenschaften), not bought from private insurers.
Contributions to German statutory accident insurance are owed by the employer (Unternehmer) for whose business the insured persons work. Section 150(1) SGB VII; employees do not contribute.
The keeper of a motor vehicle normally based in Germany must take out and maintain liability insurance covering the keeper, the owner and the driver. Section 1 Pflichtversicherungsgesetz (PflVG). Minimum sums insured were not reviewed.
Social insurance contributions for Saudi employees total 21.5% of salary (9.75% employee, 11.75% employer), while for non-Saudi employees the employer pays 2% for occupational hazards only, on salary capped at SAR 45,000 a month. Contribution base is basic salary plus housing allowance; rates as reported for employees covered before the new Social Insurance Law.
Secondary source. The GOSI website did not render content when opened. The new Social Insurance Law (understood to apply to new Saudi entrants from 3 July 2024 with phased pension contribution increases) is not reflected on the PwC page and was not confirmed on an official page. Reused from sa-people-013.
Saudi employers must provide workers with preventive and curative healthcare in accordance with standards set by the Minister, taking into account the Cooperative Health Insurance Law. Saudi Labor Law, Article 144. The detailed health insurance obligations under the Cooperative Health Insurance Law were not reviewed.
Employers must buy work injury compensation insurance for all employees doing manual work, regardless of salary, and for employees doing non-manual work who earn S$2,600 or less a month. Monthly salary for the threshold excludes overtime, bonuses, annual wage supplement, productivity incentive payments and allowances. Since 1 January 2021 policies must be issued by a designated insurer.
Confirmed; the S$2,600 threshold is current on the MOM page. Reused from sg-risk-007.
Singapore employers must buy and maintain medical insurance with annual coverage of at least S$60,000 for each Work Permit holder they employ, and cannot pass the cost to the worker. Ministry of Manpower rule effective from 1 July 2023 for the coverage amount; insurers pay 75% of claims above S$15,000. Details must be submitted before a Work Permit is issued or renewed. S Pass rules were not covered on this page.
A UK employer needs employers' liability insurance as soon as it becomes an employer, unless an exemption applies, such as employing only certain family members or only staff based outside England, Scotland and Wales. GOV.UK guidance for England, Scotland and Wales; Northern Ireland rules were not checked. The insurer must be authorised, which can be checked on the FCA register.
The Saudi Labor Law's work-injury chapter does not apply to establishments covered by the Occupational Hazards branch of the Social Insurance Law; otherwise the employer must provide treatment and bear its costs. Saudi Labor Law, Articles 132 and 133; work injuries are defined by the Social Insurance Law (Article 134).
No person may carry on a regulated activity, including insurance business, in the United Kingdom, or claim to do so, unless authorised or exempt. Financial Services and Markets Act 2000 s19 (the general prohibition); effecting and carrying out contracts of insurance are regulated activities.
The listing of insurance as a regulated activity is in the Regulated Activities Order, which could not yet be checked.
Insurers with their seat in Germany need authorisation from the supervisory authority to conduct business. Section 8(1) VAG.
Failure to provide adequate work injury compensation insurance is an offence punishable by a fine of up to S$10,000, imprisonment of up to 12 months, or both.
Reused from sg-risk-g03.
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