What is the minimum capital for a multistate insurer?

Under the 2025 amendments, $3 million for property and casualty across all lines. Current requirements should be confirmed with the OCS or with IICG.

How does IICG help with the multistate transition?

IICG assesses eligibility, prepares and files the amended business plan and Form CIS-002B, structures the insurer to meet Risk-Based Capital, holding company and reporting requirements, and provides ongoing compliance and management.

Puerto Rico Multistate International Insurers (3-M, 4-M, 5-M)

In 2025, Puerto Rico Law 130 amended Chapter 61 of the Insurance Code to create new multistate designations for international insurers and reinsurers. The Office of the Commissioner of Insurance can now grant Subclass 3-M, 4-M and 5-M status to entities that already hold Class 3, 4 or 5 authority.

The change is significant: it opens a path for a Puerto Rico international insurer or reinsurer to operate across the U.S. mainland, aligned with National Association of Insurance Commissioners (NAIC) standards, while keeping its Puerto Rico platform.

What the multistate categories allow

Operate as an authorized insurer in at least one U.S. state in addition to Puerto Rico.
Act as an accredited or certified reinsurer in other states.
Write reinsurance covering risks across multiple states.
Operate as an excess or surplus lines insurer across jurisdictions.

Key requirements

A multistate insurer is generally held to standards similar to a domestic U.S. insurer. Under Law 130-2025 these include:

NAIC annual statement and statistical reporting.
Risk-Based Capital (Articles 45.010 to 45.130).
Holding company regulation under the NAIC model law.
Corporate governance reporting.
Admitted assets and liabilities, and investment limitations, applicable to domestic insurers.
A single-risk limit of 10% of surplus, and credit for reinsurance.
Participation in the guarantee association of each state where it does business.
Minimum capital of $3 million (property and casualty, all lines).

Qualifying insurers have a one-year transition period to submit an amended business plan. This page is general information, not legal advice; specific eligibility and current requirements should be confirmed with the OCS or with IICG.

Why it matters

Access to multistate U.S. markets from a Puerto Rico platform.
Alignment with NAIC accreditation standards.
Reduced regulatory redundancy across states.
A stronger competitive position for international insurers and reinsurers.

How IICG helps

IICG guides international insurers and reinsurers through the multistate transition end to end:

Assess eligibility for Subclass 3-M, 4-M or 5-M.
Prepare and file the amended business plan and Form CIS-002B with the OCS.
Structure the insurer to meet Risk-Based Capital, holding company and reporting requirements.
Provide ongoing management and compliance as your insurer or captive manager.

Frequently asked questions

What are the Subclass 3-M, 4-M and 5-M categories?

New multistate designations created by Puerto Rico Law 130 of 2025 for international insurers and reinsurers that already hold Class 3, 4 or 5 authority, allowing them to operate across U.S. states while keeping Puerto Rico authorization.

Who qualifies for multistate status?

International insurers and reinsurers with existing Class 3, 4 or 5 authority that meet the NAIC-aligned standards in Law 130-2025. IICG can assess your eligibility.

What is the minimum capital?

Under the 2025 amendments, $3 million for property and casualty across all lines. Confirm current requirements with the OCS or IICG.

Exploring multistate status?

Talk to IICG

Multistate International Insurers in Puerto Rico