SINGAPORE Law and Practice Contributed by: Simon Goh and Wang Ying Shuang, Rajah & Tann Singapore LLP
With the exceptions of the above types of (re)insurers, the applicant must have a presence in Singapore in order to be licensed as a (re)insurer. Typically, offshore insurers would choose to either incorporate a subsidi- ary company in Singapore or establish a branch office. There are two main regulatory requirements and pro- cedures when setting up a new insurance company in Singapore: • first, an applicant would have to satisfy the relevant licensing requirements, depending on the type of insurance business it wishes to underwrite in Sin- gapore (see 2.2 Writing of Insurance and Reinsur- ance ); and • secondly, an applicant would have to comply with the corporate regulatory requirement of registering the business with the Accounting and Corporate Regulatory Authority as a branch of a foreign com- pany or incorporating a Singapore company, under the Companies Act 1967. Whilst there is no express legislation or regulation to recognise overseas insurance licences through “pass- porting”, given that the MAS takes into account the domestic and international rankings, credit ratings and track record of an applicant for a (re)insurance licence, amongst other factors, the insurance licence held by an applicant’s head office or parent company may be relevant in assessing an application for a (re) insurance licence. 3.2 Fronting There is no express legislation or regulation against fronting but, whilst not prohibited, the practice is typi- cally frowned upon by the MAS. 4. Transaction Activity 4.1 M&A Activities Relating to Insurance Companies M&A of insurance companies and the transfer of insurance portfolios are regulated in Singapore. Prior approval from the MAS is required before an entity can obtain effective control or become a substantial shareholder of a licensed insurer incorporated in Sin- gapore. Likewise, MAS approval is required for the transfer of the whole or part of the insurance business
of a Singapore licensed insurer. The transfer (which is akin to a statutory novation) must further be confirmed by the High Court of Singapore. The Singapore insurance industry has witnessed a spike in cross-border M&A activities in the past few years, but activity appears to have slowed down in 2025. However, as Singapore is the insurance and reinsurance hub of Asia and has a relatively stable geopolitical and legal landscape, it remains the next frontier of further growth as foreign insurers look to gain a foothold or reinforce their presence in Asia. As foreign insurers with strong appetites for growth con- tinue to explore new business lines and distribution channels in the emerging markets in South-East Asia, this is likely to be accompanied by an increasingly robust demand for insurance and reinsurance. Apart from cross-border M&A deals, as the market becomes more saturated and the existing players explore ways to consolidate their presence and grow their market share in Singapore, 2025 saw an increase in domestic restructuring activities. For example, Lib- erty announced its plans to restructure its Asia-Pacific insurance business in 2025 with the transfers of its insurance business in Singapore from Liberty Insur- ance Pte Ltd to Liberty Specialty Markets, which took effect on 1 January 2026, and the creation of a com- bined Liberty brand in Asia. Smaller scale business reorganisations were also undertaken by Allianz and RGA in Singapore. 5. Distribution 5.1 Distribution of Insurance and Reinsurance Products Besides direct marketing and sales of insurance products by the insurers (usually through the insur- ers’ websites), the dominant distribution channel for most insurance products in Singapore is sales through intermediaries such as insurance agents and brokers. Apart from these traditional methods of distribution, bancassurance (which involves collaboration between a bank and an insurance company for the insurer to sell its products to the bank’s client base) and, more recently, web-based insurance product comparison aggregators and embedded insurance (where insur-
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