Glossary
Captive insurance company
A licensed insurer owned by the business or group it insures, formed to underwrite their own risks rather than buying all coverage from outside insurers.
Also called: captive, captive insurer, single-parent captive, group captive, pure captive
A captive is an insurance company that a business, or a group of businesses, owns to insure its own risks. A single-parent captive covers its owner and affiliates; a group captive pools similar companies, such as members of an industry association. Captives are licensed in a domicile such as Vermont, Delaware, Utah or Bermuda, take in premiums, hold reserves and pay claims, and buy reinsurance for the layers they don't want to keep. Because most states require a licensed insurer to issue a policy, a fronting carrier often issues the policy and cedes the risk to the captive.
The appeal is control and cost: the owner keeps underwriting profit and investment income that would otherwise go to a commercial insurer, can insure risks the market handles poorly, and gets a stake in claims and loss control. The risks are real capital, an actuarial feasibility study, annual regulatory filings, and volatility if losses spike.
Tax treatment is the third rail. Premiums are deductible only if the arrangement is real insurance, with risk shifting and distribution. Under IRC section 831(b), a small captive can elect to be taxed only on investment income if its premiums do not exceed $2.9 million for taxable years beginning in 2026. Final regulations effective January 2025 require disclosure of certain micro-captive transactions. The guide on what is a captive insurance company and how does it work? explains who should consider one, and Micro-captives (831(b)) and the IRS: rules, red flags and reporting covers the scrutiny.
Last reviewed October 10, 2026