Oct 2026
The Bermuda Monetary Authority (BMA) has completed its consultation on proposed new rules, the Insurance (Internationally Active Insurance Group Supervision) Rules 2026 (the “Proposed Rules”) for the supervision of Internationally Active Insurance Groups (IAIGs). The proposals would introduce enhanced qualitative requirements aligned with the Common Framework for the Supervision of IAIGs (“ComFrame”). ComFrame was adopted by the International Association of Insurance Supervisors in 2019 and currently applies to 59 IAIGs across 19 jurisdictions, three of which are domiciled in Bermuda.
This alert summarises the key aspects of the consultation and the Proposed Rules and highlights what identified IAIGs should be considering prior to publication of the final Rules, expected in Q4 2026.
What Do the Proposed Rules Cover?
The Proposed Rules operate as an overlay to the existing group supervision framework and introduce enhanced requirements in the following areas:
- Corporate governance, including clearer responsibilities for the Head of the IAIG, group-wide strategy articulation within the Group Solvency Self-Assessment and board competence expectations;
- Material change notifications, requiring the Head of the IAIG to report material changes to the BMA, including changes to legal structures, governance arrangements, strategy and business activities;
- Risk management and internal controls, including documentation of material differences across legal entities, coordination of group-wide control functions and quarterly reporting obligations;
- Enterprise risk management for solvency purposes, including use of economic capital models, independent review of the ERM framework at least once every three years and group-wide reinsurance and claims management strategies;
- Investment risk management, including group-wide investment policies, enhanced due diligence and monitoring of concentration risk;
- Liquidity risk management, including stress testing, contingency funding arrangements and liquidity evidence packs for supervisory review;
- Supervisory reporting, crisis management and coordination among supervisors, including potential establishment of Crisis Management Groups.
How Will the Proposed Rules Affect Bermuda IAIGs?
The Proposed Rules place primary responsibility on the Head of the IAIG for ensuring group-wide compliance. Insurance groups designated as IAIGs should assess their existing governance, risk management and reporting frameworks against the enhanced standards. Key considerations include whether current group-wide control functions meet the proposed coordination and independence requirements, whether ERM frameworks adequately address cross-border risks and intra-group exposures, and whether liquidity risk management processes are sufficiently forward-looking.
While the BMA has noted that the expectations reflected in the Proposed Rules are broadly consistent with existing supervisory practices already applied in the BMA’s ongoing supervision of IAIGs, the Proposed Rules introduce new specific obligations that will require IAIGs to enhance their documentation, reporting and internal processes.
How Can Conyers Help?
The consultation period closed on Wednesday, 30 September 2026. The Conyers Bermuda Insurance and Reinsurance Practice is available to assist with reviewing the Proposed Rules and preparing for implementation. Please contact your usual Conyers representative for further guidance.