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White paper

Managing non-traditional reinsurance in an era of heightened regulatory scrutiny

15 October 2026

Non-traditional reinsurance, particularly asset-intensive reinsurance (AIR), also known as funded reinsurance, has become a major focus for regulators. Across the five jurisdictions of the United States, United Kingdom, Bermuda, Japan and Hong Kong, regulators are looking at whether:

  • These transactions deliver genuine risk transfer
  • Capital relief is proportionate to the underlying risks
  • Collateral and supporting assets remain reliable under stress
  • Cedents are prepared for counterparty deterioration or recapture

Despite regulators' common concerns, the five jurisdictions are taking different approaches. Bermuda, as a key global reinsurance jurisdiction, focuses more on supervising reinsurance entities. The United States started with a reserve-adequacy lens and is now planning to directly address the recapture risk in its risk-based-capital framework. In the United Kingdom, the focus is on capital calibration and the incentives created by the current framework. Japan is moving from a narrower legal concept of financial reinsurance toward a broader AIR supervisory framework centered on effective risk transfer, collateral security, recapture stress testing and governance. And the Hong Kong Insurance Authority’s latest proposal would require pre-approval for certain AIR and finite reinsurance arrangements, while also strengthening governance around collateral management, investment strategy, recapture planning and counterparty assessment.

Still, overall, supervisory frameworks are converging on a more demanding standard for non-traditional reinsurance. The differences lie less in what regulators care about than in how they intervene: the United States through reserve and risk-based-capital mechanics; the United Kingdom through capital recalibration and structural incentives; Bermuda through transaction approval and active supervision; and Japan and Hong Kong through governance and risk-transfer discipline.

In this paper, we discuss the following:

  • Why asset-intensive and finite reinsurance are under scrutiny
  • Key structures and market uses of asset-intensive reinsurance
  • Recent regulatory developments by jurisdiction
  • Common themes, key differences and strategic implications
  • What cedents should do now
  • How independent actuarial support can help
  • Our outlook and concluding observations

Download the full paper (PDF).


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