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.
Strict local placement: the UAE
Federal Decree-Law No. 6 of 2025 provides that insurance of property and liabilities in the UAE may only be carried on by licensed insurers, prohibits buying cover for UAE risks from insurers abroad, and bars resident companies from insuring their UAE staff with foreign insurers. Overseas cover is allowed only where local cover is unavailable or local insurers cannot or will not provide it, or for other reasons the Central Bank decides.
Licensed UAE insurers may reinsure inside or outside the UAE, so a global programme normally uses a local policy fronted by a UAE insurer and reinsured to the global carrier or captive. Foreign insurers can operate onshore only through a branch or agent; financial free zones such as the DIFC have their own regulator.12345
EU passporting, UK authorisation and US surplus lines
Insurers from other EU or EEA states can write German business through a branch or cross-border services after their home supervisor notifies BaFin, while insurers from outside the EU and EEA need German authorisation to write primary or reinsurance business. In the UK, carrying on insurance business without authorisation or exemption breaches the general prohibition.
In the US, non-admitted (surplus lines) insurance is regulated, and premium tax collected, only by the insured's home state. Singapore licenses insurers under the Insurance Act, with separate categories for licensed insurers, authorised reinsurers, marine, aviation and transit insurers and foreign insurers.67891011
| Market | Rule | Exception or route | Source |
|---|---|---|---|
| UAE (onshore) | Risks in the State only with licensed insurers; no foreign cover for UAE staff | Cover unavailable locally or other Central Bank reasons; reinsurance abroad allowed | CBUAE Rulebook, Decree-Law 6/2025 Art. 82 |
| Germany | Non-EU/EEA insurers need authorisation | EU/EEA insurers via branch or freedom of services | VAG §§ 61, 67 |
| United Kingdom | Insurance business requires authorisation or exemption | Not researched in detail | FSMA 2000 s19 |
| United States | Non-admitted placement governed by insured's home state | State surplus lines rules | 15 U.S.C. 8201-8202 |
| Singapore | Insurers licensed under the Insurance Act | Foreign insurer category exists; detail not reviewed | MAS |
Decisions to make
- Does any country in the programme require local placement?123In the UAE a policy from a foreign insurer for UAE risks or UAE staff breaches the law unless an exception applies.
- Is the global insurer authorised or passported in each EU country?67Non-EU insurers need German authorisation; EU insurers can passport.
- Which US state is the insured's home state?910That state alone governs non-admitted placement and collects premium tax.
- Will local policies be reinsured to the global carrier or a captive?4Fronting with reinsurance abroad is permitted in the UAE and is the usual compliant structure.
Documents usually needed
- Global programme schedule showing local policies and fronting insurers
- Reinsurance or fronting agreements between local insurers and the global carrier or captive
- Evidence of unavailability of local cover where relying on an exception
- Register checks confirming each insurer's licence or passport
- Premium tax filings for surplus lines placements
Common mistakes
- Covering UAE employees under a group medical policy issued abroad
- Assuming a UK insurer can still passport into Germany
- Relying on a global policy's difference-in-conditions cover without checking local placement law
- Paying surplus lines premium tax in the wrong US state
Questions businesses ask
Can a UAE subsidiary be added to the parent's global policy?
Not directly for UAE risks or UAE staff unless an exception applies; the usual route is a policy from a UAE-licensed insurer reinsured to the global insurer.1234
Can an EU insurer cover German risks?
Yes, through a branch or cross-border services after its home supervisor notifies BaFin.6
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- India's rule requiring Indian assets to be insured with Indian insurers (Insurance Act section 2CB) could not yet be checked because India Code refused automated access.
- Saudi Arabia's local placement rules and the Insurance Authority's role were not confirmed.
- Singapore's rules on placing Singapore risks with unlicensed overseas insurers, and UK rules on buying cover from non-UK insurers, were not reviewed in detail.
- Whether the AED 100 million branch guarantee reported under the 2023 decree-law continues under Decree-Law No. 6 of 2025 was not confirmed; the repeal clause was not visible.
- France was not researched.
Sources and review status
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.
In the UAE, insurance or insurance brokerage of property in the State, or of liabilities arising there, may only be carried on by insurance companies licensed under Federal Decree-Law No. 6 of 2025. Federal; Article 82(1). Financial free zones (DIFC, ADGM) have their own regulators.
UAE law prohibits buying policies from insurers outside the State to cover funds, property or liabilities in the State, and prohibits resident legal entities from insuring their in-country staff with foreign insurers. Federal; Article 82(3) of Federal Decree-Law No. 6 of 2025.
Insurance with an insurer outside the UAE is permitted where the required cover is not available in the State, where local insurers refuse or cannot provide it, or for other reasons decided by the Central Bank. Article 82(4); the Board may issue regulations setting conditions.
A UAE insurance company may reinsure with another reinsurance company inside or outside the State. Article 82(2); this is the route by which UAE risks written by a licensed insurer can be ceded to group captives or overseas reinsurers.
The US State Department reports that foreign insurance companies can practise in the UAE only through a branch office or an insurance agent, and that a foreign insurer's branch must lodge an irrevocable bank guarantee of AED 100 million for insurance or AED 250 million for reinsurance. Described under Federal Decree-Law No. 48 of 2023 on regulating insurance activities. Whether these figures continue under Federal Decree-Law No. 6 of 2025 was not confirmed.
Secondary government source describing UAE law; may reflect the 2023 decree-law rather than the 2025 decree-law.
Insurers based in another EU or EEA state may write business in Germany through a branch or by providing services cross-border, after notification by their home supervisor. Section 61 VAG (Solvency II passporting); a branch may start two months after BaFin receives the home-state notification.
An insurer based outside the EU and EEA that wants to write primary insurance or reinsurance business in Germany needs authorisation from the German supervisory authority. Section 67(1) VAG; certain third-country reinsurers are exempt under conditions in the second sentence.
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.
Under US federal law, no state other than the insured's home state may require premium tax payment for nonadmitted (surplus lines) insurance. 15 U.S.C. 8201(a), part of the Nonadmitted and Reinsurance Reform Act (federal rule allocating state authority).
Unofficial reproduction of the US Code text.
The placement of nonadmitted insurance in the US is subject to the statutory and regulatory requirements solely of the insured's home state. 15 U.S.C. 8202(a); state surplus lines rules then apply.
Unofficial reproduction of the US Code text.
Insurers and insurance brokers in Singapore are licensed and governed under the Insurance Act, and insurers may operate as licensed insurers, authorised reinsurers, approved marine, aviation and transit insurers or foreign insurers. Monetary Authority of Singapore overview; the detailed rules on placing Singapore risks with unlicensed overseas insurers were not reviewed.
Questions on this topic
11 statements on non-admitted insurance and local placement rules
