What Act 130 Really Changed for International Insurers in Puerto Rico

Rubén A. Gely-Ortiz | JANUARY 7, 2026 | IICG

As we close the book on 2025, it’s clear that this was not just another year of incremental change for Puerto Rico’s International Insurance Center (CIS). It was a year of definition.

The passage of Act 130-2025 quietly—but decisively—marked a turning point for international insurers operating from Puerto Rico. Not because it reinvented the model, but because it clarified it. And clarity, in a regulated industry, is power.

From Flexibility to Credibility

For years, Puerto Rico’s value proposition as an international insurance domicile rested on flexibility: innovative structures, segregated asset plans, favorable tax treatment, and access to global risk. That flexibility attracted capital and talent—but it also raised legitimate questions from other U.S. jurisdictions. Act 130 addressed those questions head-on.

By creating the 3-M, 4-M, and 5-M sub-classes, Puerto Rico formally aligned international insurers that operate across U.S. states with the NAIC accreditation framework, while keeping the CIS model intact. In plain terms: if you want to play in multiple states, you now play by the same solvency, governance, and reporting rules as everyone else.

The Message to the Market Was Clear

The Circular Letter issued by the Office of the Commissioner of Insurance later in the year removed any remaining ambiguity: international multi-state insurers are subject to the same core standards applied to traditional U.S. insurers—capital adequacy, governance, investments, reinsurance, risk management, and guaranty fund participation where required.

This wasn’t about tightening screws. It was about eliminating regulatory arbitrage.

And that matters. Because credibility is what allows Puerto Rico to sit at the same table as Vermont, Delaware, Texas, or New York—without a footnote.

Why This Matters Beyond Compliance

There’s a bigger story here.

Puerto Rico didn’t choose the easy path in 2025. It chose the durable one.

Act 130 strengthens:

• Reciprocity with U.S. jurisdictions

• Regulatory confidence for cedents and counterparties

• Long-term sustainability of the CIS

• Puerto Rico’s standing within the NAIC ecosystem

It also sends a signal to serious operators: this is a jurisdiction for builders, not just tourists.

What 2025 Taught Us

If 2024 was about growth, 2025 was about discipline.

The industry proved it could adapt without losing its identity. Structures like captives, SAPs, and international reinsurance platforms remain viable—but now they sit within a framework that regulators, auditors, and counterparties can trust.

That’s how markets mature.

Looking Ahead to 2026

The work isn’t done. Implementation matters more than legislation. Business plans must be updated. Capital structures refined. Governance strengthened. Some players will adjust. A few may exit.That’s healthy. Puerto Rico’s International Insurance Center is no longer just an attractive option—it’s a credible one. And in this industry, credibility compounds.