The Reinsurance Registration System (the “System”) was established by the former PRC insurance authority–China Insurance Regulatory Commission, now known as the National Financial Regulatory Administration (NFRA), as an essential financial infrastructure to strengthen supervision over the PRC reinsurance market and enhance regulatory efficiency. Officially launched on January 1, 2016, the System has been managed and technically upgraded by the Shanghai Insurance Exchange (SHIE) since February 2018. All overseas reinsurance counterparties planning to cede from PRC entities, are required to register and maintain up-to-date information in the System as a prerequisite for conducting reinsurance transactions within PRC.
The core objectives of the System are to provide dynamic supervision through the registration of reinsurance counterparties; to ensure robust risk prevention by verifying the qualifications and compliance of counterparties and mitigating risks; and to promote greater transparency in the reinsurance market, advancing alignment with international standards and regulatory practices.
1. Qualification Criteria
To be eligible for registration in the System, overseas reinsurers must meet several key requirements:
- Financial Strength: A financial strength rating of at least S&P A- (or equivalent from Moody’s, A.M. Best, or Fitch).
- Capital Requirements: Minimum actual capital plus reserves of RMB 200 million (or equivalent in other currencies).
- Solvency Compliance: Compliance with solvency requirements in their home jurisdiction.
- Regulatory Record: No major legal or regulatory violations in the past two years.
2. Material List
Qualified overseas reinsurers must prepare and submit a set of documents and information, including but not limited to:
- Company name, address, and contact details
- Business license or equivalent documentation
- Operating permit from their home insurance regulator
- Audited annual financial reports for the past three years
- Information on major shareholders
- Financial strength ratings (optional but recommended)
- Proof of solvency and regulatory compliance issued by the home regulator
- Data related to reinsurance business ceded from China (if any)
- Settlement bank account information
3. Application Procedure
The registration process involves the following steps:
- Submission of Reference Letter:
A “recommendation institution” (an entity that has, or will have, a reinsurance relationship with the applicant) uploads a Reference Letter to the System. If the applicant has an affiliated enterprise in China, that entity should act as the recommender.
- Temporary Account Creation:
The System will automatically send an email containing a temporary username and password to the reinsurer.
- Submission of Application Materials:
The reinsurer needs to log into the System and submits all required documents within 15 days of receiving the account credentials.
- System Review:
The System will review the materials automatically, and if all requirements are met, the reinsurer will be added to the active list immediately.
4. Ongoing Compliance Obligations
Registered reinsurers have the following ongoing compliance obligations:
- Registrations must be renewed every three months.
- Key documents, such as audited annual financial reports and proof of regulatory compliance, must be updated annually.
- Reinsurance business data must be updated quarterly.
- Any significant changes, such as solvency issues, corporate restructuring, or regulatory actions, must be reported within 15 days.
Registering as an overseas reinsurer in China requires not only meeting the initial eligibility criteria but also careful preparation of documentation and ongoing commitment to compliance. While the process is straightforward, regular renewals are essential to maintaining active status within the System. Once the Registration is done, the reinsurer will enter the active list of the System making it eligible to cede from PRC entities.
