PPLI market and regulatory developments: Singapore, Bermuda, Luxembourg and the United States

Any account of the PPLI market has to start with a negative: there is no separate official statistic for PPLI. The Life Insurance Association Singapore (LIA) reports new business in three categories, participating, non-participating and investment-linked, and the investment-linked column combines retail ILPs with high-net-worth VUL / PPLI. The figures the Monetary Authority of Singapore (MAS) publishes on assets under management and on the numbers of single family offices and VCCs describe the wealth management environment PPLI sits in, not PPLI itself. This page brings together that context data, registration and consolidation activity in the carrier jurisdictions, and US regulatory investigation and legislative proposals, with the basis, date and nature of the source stated for each item. Readers can use it to judge where PPLI sits, but not to infer its sales, returns or trends.

The basis first: why there are no PPLI figures

There are three reasons. First, PPLI has no separate statistical category in Singapore: in LIA data it falls under investment-linked products, and in regulation it is subject to the notices and disclosure requirements for investment-linked policies. Second, carriers are spread across jurisdictions: a Singapore resident's PPLI policy may be issued by a Singapore-licensed life insurer, a Bermuda long-term insurer or a Luxembourg insurer, so the data go into different regulators' statistics and are not broken down by client location. Third, the products are privately placed: for products offered privately to Accredited Investors, insurers do not usually publish sales of individual products. All the figures below should therefore be read as "environment", not as "PPLI market size".

Singapore: context data on wealth management

The link between these data and PPLI is indirect. Discretionary assets making up more than half the total indicates a large base of families with existing private-bank discretionary portfolios, which are the typical source of in-specie transfers into PPLI. Growth in family offices and VCCs indicates more entities that might become policyholders (see Family offices and VCCs). These are preconditions, not outcomes.

Singapore new life business: investment-linked share and large policies

Two points on the basis. First, LIA's weighted measure counts only 10% of single premiums, so the actual premium volume of single-premium products such as PPLI is far larger than their weighted figure. Second, the 44% combines retail and high-net-worth business and cannot be read as the share of PPLI or VUL.

On large policies, Manulife Singapore announced on 24 Feb 2026 that it had issued a life policy with a sum assured of US$300 million, and said it had issued 25 individual policies each with a sum assured above US$50 million over the previous 12 months; the official release did not state the product type. Great Eastern launched Great Eastern Private, a high-net-worth brand, on 3 Mar 2026; the public release did not mention PPLI, and this site draws no inference from it.

Bermuda: classes of long-term insurer and new registrations

Bermuda's Insurance Act 1978 divides commercial long-term (life) insurers into three classes by total assets (with Classes A / B for captives and ILT / IILT for innovative insurers): Class C below US$250 million, Class D from US$250 million to US$500 million, and Class E above US$500 million. Amounts in segregated accounts relating to long-term business are excluded when calculating total assets (ss 4ED–4F; consolidated version with amendment table up to Act 2026:35, accessed 23 Oct 2026).

The Bermuda Monetary Authority (BMA) Insurance Registration Statistics – September 2026 (uploaded 19 Oct 2026) record that Sun Life Bermuda Limited registered as Class C on 24 Sep 2026. From the start of 2026 to September, 3 Class C and 9 Class E insurers were newly registered, and new registrations across all classes totalled 42; in September, 9 insurance applications were considered and 8 approved. These are new registrations, not the total stock; this site was unable to obtain official figures for the stock of Bermuda long-term insurers by class and makes no estimate. According to a Sun Life press release (1 Oct 2026), Sun Life Bermuda Limited is a subsidiary of Sun Life Assurance Company of Canada regulated by the BMA, and its private wealth business has operating locations in Bermuda, Dubai, Hong Kong and Singapore. This describes institutional footprint, not the merits of any product.

Luxembourg: consolidation among carriers

The core features of Luxembourg unit-linked policies are the "Triangle of Security" and policyholders' "super-privilege" (see Carriers in three jurisdictions). At carrier level, Utmost Group completed its acquisition of Lombard International in December 2024, and the business was renamed Utmost Luxembourg; after the combination, assets under administration were about £107.1 billion (about US$139.5 billion) with about 200,000 clients (as of 30 Jun 2025) (WealthBriefing, 6 Nov 2025, secondary). Separately, according to an industry interview, Swiss Life Luxembourg has offered PPLI for more than 35 years, and Swiss Life's Singapore entity specialises in VUL and PPLI, covering six Asian markets (Hubbis, 18 Mar 2025, secondary; licence categories as shown in the MAS Financial Institutions Directory). This site was unable to obtain the Luxembourg regulator CAA's statistics on unit-linked premiums and gives no figures. The institutions named above come from public press releases and industry media; the list is incomplete and is not a recommendation.

United States: from the 2024 investigation report to the 2026 bill S.4279

On 21 Feb 2024, the Democratic majority staff of the US Senate Finance Committee published an investigation report on PPLI, based on data obtained from seven major carriers. As reported by the media, there were about 3,000 in-force policies with total face value of about US$40 billion (as of end-2022), and the report called for stronger reporting and stronger enforcement of the investor-control rules (Accounting Today, 21 Feb 2024; this site was unable to read the original report, and figures differ slightly between media outlets).

On 13 Apr 2026, Senator Wyden introduced S.4279, the Protecting Proper Life Insurance from Abuse Act (govinfo bill text). According to a law firm briefing (Sidley, 4 May 2026, secondary), the bill would add a new §7702C. A variable contract that the holder may buy only on the basis of income, assets or a qualification declaration would be a "private placement contract", and would lose life insurance or annuity tax treatment unless its segregated account proportionately supports at least 25 private placement contracts. Contracts held by related persons would be aggregated; private placement contracts issued abroad and sold to US persons would be directly covered; existing policies would have a 180-day adjustment period; and issuing or reinsuring companies would report annually to the IRS. The bill is so far only a proposal and has not become law; whether it passes, and whether its text changes, is uncertain.

For non-US holders, the significance lies in the direction rather than the figures: US scrutiny of PPLI is increasing. Families preparing to relocate to the United States, or with US persons among policyholders or beneficiaries, should treat it as a compliance signal (for the rules, see Tax compliance). The above is US market information with a legislative-advocacy background and should not be used to describe Asian markets.

Hong Kong for comparison

Provisional 2025 statistics published by Hong Kong's Insurance Authority show new office premiums for long-term business (excluding retirement scheme business) of HK$330.9 billion, up 50.6% year on year, and total long-term premiums of HK$827.0 billion, up 29.7% (IA, 24 Apr 2026). These too are whole-market figures and cannot be read as the size of high-net-worth or PPLI business. Industry media coverage of the 2025 HNW Insurance Summit in Singapore reported that PPLI is often positioned as a succession and structuring tool, particularly relevant to families moving from low-tax to high-tax jurisdictions; that VUL is used more where higher cover is needed, and the two do not compete; and that Hong Kong clients can also access products offered from Singapore and Bermuda (Hubbis, 4 Sep 2025, secondary). These are practitioners' views, not statistical findings. For product and regulatory differences between Hong Kong and Singapore, see the sister sites vul.hk and privatebank.hk.

What these data cannot tell you

1. They cannot tell you PPLI's sales or growth: every figure is a context or combined measure.
2. They cannot tell you PPLI's returns: growth in assets under management reflects market performance and net inflows and has nothing to do with any policy account; account value is not guaranteed and may fall below premiums paid.
3. They cannot tell you which carrier jurisdiction is "safer": new registrations, acquisitions and ratings describe institutional activity, not a guarantee of policy value.
4. US regulatory conclusions cannot be applied directly to holders in Singapore or Hong Kong, though they can serve as a reference for compliance trends.

Figures on this page are as at each institution's publication date; for later updates, refer to the original pages listed in Sources. Readers who want this interpreted for their own situation can register their needs through the contact details on this site.