Entering the US Insurance Market: Three Routes for Non-US Insurtechs

Non-US insurtechs often arrive in the US with a proven product and a plan to launch in months. The regulatory reality is slower than the plan, and it is fragmented. Insurance in the US is overseen primarily by states, so one launch is many conversations.

There are three practical routes. They are not exclusive, and most serious entrants use more than one over time.

Route 1: Become a licensed insurer

A company that wants to carry risk as an admitted insurer deals with state regulators and a domiciliary state. NAIC describes the framework as state-based, with solvency monitored by the domiciliary state. This route offers the broadest consumer-facing position, since admitted insurers participate in state guaranty funds. The cost is time, capital and the need to satisfy each state in which you want to operate.

For most embedded entrants this is a destination, not a starting point.

Route 2: The surplus lines market

Surplus lines is the non-admitted market for risks the admitted market does not cover, and it matters to entrants with specialized or new coverage. The NAIC's surplus lines page gives the scale: direct premiums written passed $100 billion in 2023 and grew 12.2% in 2024 to $131 billion, about 12% of a US property and casualty market that wrote over $1 trillion. US insurers wrote 75% of 2024 surplus lines premium, Lloyd's syndicates 16% and non-US insurers 9%.

Non-US insurers can participate when they are admitted to the NAIC Quarterly Listing of Alien Insurers. Those insurers are overseen by the NAIC International Insurers Department and must follow its Plan of Operation. The NAIC publishes the listing quarterly.

Three points deserve emphasis for a business planning around this route:

The transaction is what is regulated. A licensed surplus lines broker must confirm that the insurer meets the eligibility criteria in the state and must remit surplus lines premium tax to the home state. "Non-admitted" does not mean unregulated.
Guaranty fund protection is not available for surplus lines policies. That affects how partner brands and enterprise buyers view the product, and your disclosures should anticipate it.
The route suits specific risks. NAIC describes surplus lines as the home of new coverages without loss history that are hard to price with standard actuarial methods. A high-volume, standardized consumer add-on is usually a different fit.

Route 3: Partner for capacity and distribution

Many entrants avoid building a carrier first. They work through a licensed fronting insurer and a US MGA, with reinsurance behind the program. Morningstar DBRS reports MGA-sourced premium of $90.4 billion in 2024, about 9% of US P&C, up 90% in five years against 49% for the sector, across more than 1,000 MGAs. This is the route where the market is, and where capacity providers are most experienced at onboarding specialists.

It is not a shortcut around scrutiny. The carrier is accountable for oversight, so expect the oversight standards in the NAIC's MGA model to show up in your contract: authority limits, records access, claims reporting, audits. S&P Global Ratings has noted that reinsurers see MGAs as a way into the US excess and surplus lines market but warns that growth must come with governance, alignment of interests and strong controls. Capacity partners will ask you about those things, so prepare answers.

Choosing a route

Question	Points toward
Is the product a standard personal line sold at high volume through partners?	Licensed carrier capacity (routes 1 or 3)
Is it a specialized or new risk with little loss history?	Surplus lines (route 2), through a licensed broker
Do you need to be live within a year, with limited US capital?	Route 3, with a clear plan for the MGA's licensing
Is US scale part of the long-term plan?	Route 3 first, with route 1 as a defined milestone

These are our judgments, not regulatory classifications. Each requires review against the lines and states you intend to write.

Three mistakes we see in plans

Treating "the US" as one regulator. Build a state-by-state plan, with the first states chosen for fit, not size.
Planning technology before structure. The product's architecture should follow the licensing and capacity structure. The reverse costs rework.
Leaving the distribution licence question to the end. If your partner brands will sell the product, the question of who needs a licence in each state comes before the integration, not after. See our piece on point-of-sale licensing.

Treaty-level matters can also apply: the Treasury's Federal Insurance Office is charged with determining whether state insurance measures are preempted by covered agreements. Ask counsel whether any of that is relevant to your home jurisdiction.

Clark Embedded Advisors helps non-US insurtechs choose and sequence a US entry route. Book a call and bring your current stack, product lines and target states: embedinsurance.net/contact.

General information, not legal advice. Market-entry requirements depend on line, state and corporate structure.