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ARTICLE · 06 MARCH 2026

Unit-linked Life Insurance Investment Rules: Same Framework, New Lens

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On 1 February 2026, the Commissariat aux Assurances ("CAA") published Circular Letter 26/1 on the investment rules applicable to life insurance products linked to investment funds.

LuxembourgFinance and Banking
Adrien Pierre
Adrien Pierre
Jeanclaude Lacatena
Jeanclaude Lacatena

Implications of CAA Circular Letter 26/01

On 1 February 2026, the Commissariat aux Assurances (“CAA”) published Circular Letter 26/1 on the investment rules applicable to life insurance products linked to investment funds. The new circular applies to contracts issued as from that date. It does not formally repeal Circular Letter 15/3 of 2015, as coordinated in 2019, which continues to govern legacy contracts. The two regimes therefore coexist. Insurers should be aware that, while Circular 26/1 leaves the substantive investment framework largely unchanged, it sharpens supervisory expectations in relation to the governance of more complex products. 

Same framework: investment rules largely maintained

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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