Cayman's application for recognition by U.S. insurance regulators has drawn on-the-record opposition from Athene, the annuity writer owned by Apollo Global Management, which wants gaps it identifies in capital, reserving, disclosure and supervisory staffing closed "before recognition is granted, not after."

The 11-page letter carries the signature of Michael Consedine, Athene's head of government and regulatory affairs, and the date 3 November 2026, the day the 60-day comment period closed. Athene says it does not oppose Cayman as a jurisdiction and that some Cayman reinsurers are well run.

It is one of 10 filings on the application published by the National Association of Insurance Commissioners (NAIC), the body of U.S. state insurance regulators. Six come from Cayman's industry and support the bid: the Cayman International Reinsurance Companies Association (CIRCA), Cayman Finance, the Insurance Managers Association of Cayman (IMAC), the Cayman Islands Legal Practitioners Association, the insurance manager Blue Ocean and the owner of a licensed reinsurer, Axonic. Guardian Life, writing on all three applicants, Cayman, Guernsey and South Korea, said status should be granted only where a regime shows protection comparable to the U.S. system. Two individuals opposed.

The filings land as the same regulators design a capital charge on offshore reinsurance. Qualified Jurisdiction Status, which Cayman has applied for, lowers the collateral a U.S. insurer must post against a Cayman reinsurer. It would not lift the charge, which applies to reserves ceded outside the NAIC's reciprocal jurisdictions: Bermuda, the EU, Japan, Switzerland and the UK. Qualified status is, however, the only rung from which a jurisdiction can seek reciprocal status, the route Bermuda, Japan and Switzerland took in 2019. Athene makes that ladder its argument: reciprocal status would end collateral and exempt U.S. insurers from the charge, removing two safeguards together.

CIRCA's letter, signed by its chair, Faramarz Romer, discloses that the Government "has proposed a phased application beginning with property and casualty". The charge targets life and annuity business. Athene's letter assumes the application covers both and does not mention phasing. On those documents, the first phase would not reach the business the charge targets.

Athene also counts about 26 staff in the insurance supervision division of the Cayman Islands Monetary Authority (CIMA). CIRCA's letter says the Premier has confirmed amendments to the Public Authorities Act to raise salary bands, with added budget for CIMA to recruit.

The Caymanian Journal (TCJ) put its reading of the two tiers to the Ministry of Financial Services and Commerce, CIMA and CIRCA by email on 9 November, a public holiday, and asked each whether it is wrong, and if so why, by 11 November. CIRCA acknowledged the questions on 9 November and said it would be back in touch; it had not answered them by the deadline. The Ministry and CIMA had not responded by the deadline.

Under the NAIC's Credit for Reinsurance Model Law, a U.S. insurer that passes risk to a reinsurer in a qualified jurisdiction can take credit for that cover against a lower collateral requirement than it must hold for reinsurers elsewhere, which makes Cayman cheaper to use: the model law requires a certified reinsurer in a qualified jurisdiction to secure its obligations "at a level consistent with its rating". The reciprocal tier goes further, resting on agreements that provide for "the elimination, under specified conditions, of collateral requirements". Seven jurisdictions hold qualified status: Bermuda, France, Germany, Ireland, Japan, Switzerland and the UK. CIMA lodged Cayman's application on 7 August, and the Premier and Minister for Financial Services and Commerce, André Ebanks MP, led a delegation to the NAIC's summer meeting in Columbus, Ohio, that month to press it. The NAIC meets again in Dallas from 14 to 17 November, and its notice does not say when the working group will decide.

The referral that the NAIC's Financial Condition (E) Committee sent to its Life Risk-Based Capital Working Group, dated 27 July, directs it to develop a "reinsurance recapture" capital charge on reserves ceded to reinsurers outside the NAIC's reciprocal jurisdictions, which are Bermuda, the EU, Japan, Switzerland and the UK; one of CIRCA's two letters of 23 September to that working group says the referral "directs the charge be applied only to reinsurers domiciled in non-reciprocal jurisdictions". When the Life Risk-Based Capital Working Group met on 13 October, its own summary of the comments it had received recorded "several comments around specifying treatment for qualified and other types of jurisdictions, including captives", and said: "This goes beyond the scope of the referral."

The papers published for the NAIC's Dallas meeting keep to that line. On 15 November the Life Risk-Based Capital Working Group is to consider exposing for comment a proposal titled "Recapture Risk Non-Reciprocal Jurisdiction", and on 17 November the Financial Condition (E) Committee is to consider adopting the NAIC's lists of qualified and reciprocal jurisdictions; the staff memorandum before it, dated 4 November, recommends that the seven existing qualified jurisdictions and the three reciprocal jurisdictions outside the EU and UK covered agreements retain their status, and does not mention Cayman.

What CIRCA's letter discloses

CIRCA supports the phasing "as a measured way for the Working Group to evaluate the jurisdiction". CIMA had told TCJ in October that the application seeks recognition for both property and casualty and life and annuity business, "with initial focus on property and casualty business". The capital charge, by contrast, is aimed at life and annuity business: the referral says business ceded to unauthorised reinsurers "generally comes from newer, relatively small annuity writers offering aggressive crediting rates", and CIRCA's letter cites AM Best data showing Cayman's share of U.S. life and annuity reserves ceded to reinsurers rose to 2.3% in 2025 from 2.0% a year earlier.

The letter also says the Premier "has confirmed proposed amendments to the Public Authorities Act to raise legislated salary bands, along with additional budget to enable CIMA to supplement its ranks", that Cabinet approved draft legislation in April 2026 allowing CIMA to set salaries outside the civil service pay scale, and that the Government "is also introducing changes to procurement laws to facilitate CIMA's access to consultants, advisors and secondments of individuals with specialised skills as needed". Neither point appears in the Premier's office's release of 10 August announcing the application. The published Cabinet record for 15 April 2026 says Cabinet "approved the issuance of drafting instructions to amend section 47 of the Public Authorities Act and any ancillary amendments necessary"; section 47 is headed "Terms and conditions and remuneration of staff". The record does not name CIMA or describe the amendment, and the Ministry has not published a timetable. No Public Authorities or Procurement amendment Bill appeared in the Government's 2026 Bills index on 9 November. TCJ asked the Ministry in the same email to confirm CIRCA's account.

CIRCA, formed in 2020, represents commercial reinsurers licensed by CIMA with operations in Cayman. Its members write life, annuity, and property and casualty reinsurance, most of it ceded by U.S. insurers. The letter puts the number of licensed reinsurers at 113 at the end of 2025, up from 58 at the end of 2020, holding about US$101 billion in assets, citing CIMA data. "Importantly, the majority of Cayman Islands reinsurers are established specifically to assume risks from U.S. insurers and therefore operate under ongoing scrutiny from both CIMA and U.S. insurance regulators," Mr Romer wrote. "The resulting supervisory framework is complementary to, rather than a substitute for, U.S. regulatory oversight."

The letter sets CIMA's laws, rules and practice against each of the NAIC's seven evaluation criteria and records that CIMA has a memorandum of understanding with the NAIC, signed in 2018, and bilateral agreements with the insurance departments of Florida, Illinois, North Carolina, Texas, Utah and Washington. "In CIRCA's experience, the Cayman Islands meets that standard through a combination of strong governance requirements, robust solvency oversight, independent actuarial review, active supervision, effective enforcement powers, and a demonstrated commitment to regulatory cooperation," Mr Romer wrote, urging the working group "to recommend the Cayman Islands for inclusion on the NAIC List of Qualified Jurisdictions".

The U.S. proposal

The E Committee's referral, signed by Wisconsin Insurance Commissioner Nathan Houdek, who chairs the committee, says that "as more business is ceded to jurisdictions outside the U.S., recapture risk also increases" and that "many state insurance regulators believe this risk warrants immediate attention." It says most offshore business goes to Bermuda, which U.S. regulators view favourably. The target is year-end 2027.

A second memorandum from Mr Houdek to the working group, dated 26 October, is "specific to the issue of reinsurance recapture risk for cessions to non-reciprocal jurisdictions", directs that the capital requirement be set "without regard to the probability of recapture", and says an analysis of filings under Actuarial Guideline 55 found that approximately 70% of life insurers ceding to non-reciprocal jurisdictions hold riskier asset portfolios. Neither memorandum mentions qualified jurisdictions or Cayman by name. The working group's draft minutes of its 28 October meeting record Bridgeway Analytics telling it that "more than 99% of non-reciprocal jurisdiction transactions in 2025 were with reinsurers in the Cayman Islands and Barbados", that the group had reached consensus on "a factor-based method to add back risk-based capital" for companies ceding to non-reciprocal jurisdictions, and that the comment period on any exposure "may extend into 2027".

Bermuda remains the far larger market: ALIRT Insurance Research, a U.S. analysis firm, estimates U.S. insurers had about US$2.7 trillion of ceded life and annuity liabilities at the end of 2025, of which US$1.1 trillion sat with Bermuda reinsurers. The NAIC's consultant, Bridgeway Analytics, puts about US$135 billion, 4.7%, with reinsurers in jurisdictions outside the reciprocal list, a group in which Cayman is the largest, according to CIRCA's letters of 23 September.

In those letters CIRCA argued that any charge should turn on an individual reinsurer's financial strength rather than its domicile. "Recapture risk exists across all reinsurers in varying degrees, and a charge that does not reflect that variation is not risk-based," Mr Romer wrote, adding that a jurisdiction-based charge is "anti-competitive in effect". The working group's 13 October comment summary also records the American Council of Life Insurers and Athene asking about the "treatment of reciprocal vs. qualified jurisdiction reinsurers", the question on which the group said it would not go beyond the referral. Asked what the charge would do to new business and jobs in Cayman if adopted as proposed, Mr Romer told TCJ on 29 October it was "too early to quantify" but that "a charge applied in full without appropriate consideration of the underlying risks could have a meaningful impact on the jurisdiction's competitiveness." CIRCA "is not opposed to additional capital requirements where they are justified," he said. The Insurance Managers Association of Cayman (IMAC) "is supportive of CIRCA's stance," its General Manager, Kevin Poole, said.

CIMA has not filed a letter of its own on the charge; none appears in the NAIC's published list. Asked whether it had made or intended a submission, the regulator told TCJ on 27 October that it "continues to monitor international regulatory developments that may be relevant to the Cayman Islands insurance and reinsurance sector, including initiatives being considered by the NAIC," and that "the Authority supports regulatory frameworks that are robust, proportionate and risk-based."

Athene backed the charge before it opposed the application. It wrote to the NAIC on 25 September in support of the charge, saying it "closes a real gap in the framework, one that can otherwise be used to arbitrage capital requirements across jurisdictions that offer materially different regulatory assurances." Apollo's Chief Executive Officer, Marc Rowan, told analysts in November 2024 that the capital regimes in the U.S. and Bermuda and those "in places like the Caymans and the other jurisdictions, are totally different," as reported by ThinkAdvisor, a U.S. financial trade publication. "Anytime you hear people have gone to Caymans, you should just divide the capital by two," he said. The sector's standing reply is on the record: Cayman Finance, the industry body for the financial services sector, said in a statement on 23 February 2026 that at least 100% of the U.S. statutory reserves arising from reinsurance with Cayman reinsurers are held in the U.S., either withheld by the ceding insurer or in trust accounts run by regulated U.S. trustees.

The Government's case

The application has featured in a year of Government travel on financial services. After Ohio in August, Mr Ebanks spent four days in New York and Toronto from 13 to 16 October, taking in reinsurance meetings in New York and a keynote speech at the Alternative Investment Management Association's Global Investor Forum in Toronto, the Ministry said in a release on 22 October. Parliamentary Secretary Julie Hunter MP, Gene DaCosta, the Cayman Islands Government Representative, Overseas, and Sean Whewell, Private Secretary to the Premier, travelled with him.

In New York the Premier met reinsurance firms, took part in KPMG's Cayman Islands Reinsurance Update and, on 14 October, joined CIMA's Chief Executive Officer, Cindy Scotland, for a "fireside chat" at the Cayman Islands Reinsurance Roundtable Breakfast, which CIRCA organised. The Premier called the application "a natural step forward" and set out three areas of focus: supporting the NAIC's assessment process, advancing regulatory reforms and strengthening specialist capacity as the sector grows, Mr Romer told TCJ in a written response on 29 October. Four members of CIMA's leadership team were at the breakfast, the regulator said.

In August Mr Ebanks told InsuranceERM, a London-based insurance trade publication, that there is "no plan B" in the bid. His full comment, the Ministry told TCJ on 29 October, was: "There's no plan B. You go for it all." He was referring to Cayman's ambition to win recognition for both property and casualty and life and annuity business, the Ministry said, and it "was not a statement about what Government would do if the application were unsuccessful." That ambition "remains unchanged and is being pursued through a phased approach," it said, and the Premier's broader point was that Cayman "has a strong record of Government, the regulator and industry working together to strengthen its regulatory framework and meet or exceed international standards."

Ms Hunter said in the release that the reinsurance feedback would inform the Ministry's legislative work. Asked which Bills or regulations are planned, the Ministry said it expects "some legislative and regulatory changes as the process evolves" and will be "guided by the NAIC and CIMA," and that the insurance industry will be consulted. Feedback from the New York engagements, it said, "helped inform the legislative and regulatory framework now being promoted by industry to prospective clients which is valuable beyond measure." The Ministry's written response did not include the cost of the visit, and CIMA said information on the cost of its staff's travel "can be made through our Freedom of Information request process".

Cayman Finance said the visits earn their keep. "Government-led visits help Cayman protect existing business, attract new investment, and strengthen relationships with the international institutions that use our financial services industry," a Cayman Finance spokesperson said on 26 October. "Having the Premier involved is important because businesses want to hear directly from Government about the jurisdiction's regulatory framework, economic priorities, and plans for the future."

The Ministry assesses the value of overseas financial services visits "through their contribution to policy development, regulatory cooperation and opportunities for Cayman's financial services sector," it told TCJ, and describes the programme as "sustained international engagement"; since May 2025 it has taken the Premier to London, India, Florida, Hong Kong, Shanghai, Tokyo, Washington and Columbus, Ohio, to Dublin and London in September, and to New York and Toronto in October.

The sector behind the bid

The reinsurers CIRCA speaks for are the fastest-growing part of a shift that CIMA's own figures record. The Authority licensed 110 banks at the end of 2020 and 77 at 30 September 2026, a fall of 30%: 11 Category A banks, which serve the domestic market, and 66 Category B banks, which serve non-residents. Over the same period the assets held by the 720 insurers and reinsurers it licenses for international business rose from US$70.8 billion to US$202.9 billion, almost three times as much. The figures come from CIMA's 2025 Annual Report, its key statistics for 30 September 2026 and the third-quarter insurance tables it posted in October.

The bank count has fallen every year since 2020: 110, then 101, 94, 87, 79 and 77 at the end of 2025, the report shows. Cindy Scotland wrote in her statement in the report that the sector "recorded a slight reduction in the number of licensed institutions, declining from 79 at the end of 2024 to 77 in 2025, largely reflecting consolidation and strategic restructuring at the international level". The report's comparison table shows the decline is not Cayman's alone: between 2020 and 2024 the Bahamas fell from 69 licensed banks to 62, Panama from 68 to 62, Jersey from 24 to 19, Luxembourg from 126 to 115, Switzerland from 247 to 230 and Hong Kong from 190 to 175, and Cayman's fall over those four years, from 110 to 79, was 28%.

International insurers moved the other way. The report's Figure 14 puts their assets at US$70.8 billion in 2020, US$138.7 billion in 2023, US$152.8 billion in 2024 and US$176.2 billion in 2025. By 30 September 2026 the figure was US$202.9 billion, up 15% in nine months. The number of companies grew more slowly, from 652 in 2020 to 720 at the end of 2025, where it remained at 30 September. CIMA's third-quarter tables show where the money sits: of the US$202.9 billion, the 173 licensees whose primary business is reinsurance held US$138.6 billion, or 68%, the 337 pure captives, which insure the risks of their own parent groups, held US$30.7 billion, and 632 of the 720 companies write North American risk.

Cayman Finance's February statement said reinsurance assets had grown by 341% since 2020 and attributed the growth to a shortage of capital in the U.S. life and annuity market and to reinsurance platforms sponsored by global asset managers and private equity groups. Brittany MacVicar, its associate director for insurance and reinsurance, said: "The jurisdiction has become a domicile of choice for international reinsurers seeking an efficient, well-regulated jurisdiction with English common law certainty and a deep bench of specialist expertise." James Trundle, chair of IMAC, said in a statement on 19 October: "Cayman's international insurance industry continues to demonstrate resilience, stability and sustained growth."

Jobs and the public purse

How much of the growth reaches Caymanian households is a question the sector itself is still answering. An economic impact study prepared for IMAC in March 2025 put the international insurance sector's combined impact at CI$233.85 million a year, with 256 people employed directly, 49% of them Caymanians or spouses of Caymanians. The study says it "did not capture most of the reinsurance firms." Mr Poole told TCJ on 27 October that most reinsurers are Class B(iii) licensees "whose day-to-day activities are handled by Insurance Managers" and that "relatively few B(iii) reinsurers employ staff in Cayman." Only Class D licensees, the largest category, employ staff as a licence condition, he said. IMAC has no plans to update the study before 2027. The Economics and Statistics Office's Labour Force Survey reports "financial and insurance activities" as one category, and neither the ESO nor CIMA publishes a split between banking and insurance employment or the Caymanian share of each.

The fees both sectors pay go to Government. CIMA collected CI$189.41 million in fees from regulated entities on behalf of the Cayman Islands Government in 2025, its report says, with no breakdown by sector. Under the fee schedule for 1 January 2026, a Category A bank pays CI$1 million a year and a Category B bank between CI$37,000 and CI$100,000 depending on its licence type and assets. A Class B(i) captive pays CI$10,450, a Class B(iii) insurer CI$14,850 and a Class D reinsurer CI$120,000. CIMA said in a notice dated 31 December 2025 that the annual fees for Class B(i), (ii) and (iii) insurers rose 10% this year, and that these licensees "were assessed, following consultation with the Ministry of Financial Services and Commerce, as being capable of absorbing the increases without adverse effects on their client base".

The critics' case and the data

The Tax Justice Network, a UK-based campaign group that ranks jurisdictions by financial secrecy, published research on 10 October arguing that financial sectors become a drag on growth once they pass a certain size. Asked by TCJ whether that finding bears on Cayman, Alex Cobham, the network's Chief Executive, said the research "show[s] very clearly the trap in which Cayman is caught": a dependence on finance "so extreme" that managing it down "without provoking a sudden reduction in employment" is itself the problem. "It is worrying – but perhaps inevitable – that the Cayman Government should seem to be focused on extending even further the dependence on finance," he said.

The ESO's data show the sector's weight. Financial and insurance services produced 30.0% of real GDP in 2024 and have ranked first every year since 2020, though the share has eased from 32.4% that year, the ESO said in its GDP Report 2024, and its Fall 2025 Quality of Life report found that 4.7% of respondents said they were living in poverty, down from 5.6% a year earlier.

What happens next

Cayman's application now sits with the Mutual Recognition of Jurisdictions Working Group alongside those from Guernsey and South Korea. The NAIC's notice says the evaluation and all related documentation "are private and confidential matters between the NAIC and the applicant jurisdiction", and none of the Dallas agendas published by 9 November names Cayman's application: the Reinsurance (E) Task Force takes a status report on the working group's activities on 15 November, the Life Risk-Based Capital Working Group considers exposing its recapture proposal the same day, and the E Committee considers the jurisdiction lists on 17 November.