The Industrial Insured Captive application is the licensing packet a large, sophisticated employer files with the Vermont Department of Financial Regulation to win approval for an industrial insured captive insurance company under Title 8, Chapter 141 of the Vermont Statutes. You file it when a group of related or affiliated “industrial insureds” wants to pool and self-insure its own risk through a regulated insurer instead of buying coverage on the open market.
Get one piece wrong, and your launch date slips by weeks while regulators send back questions. Vermont remains the largest captive domicile in the world, with 683 captives at the end of 2024 and roughly 41 new ones formed that year, so the reviewers who read your file have seen every shortcut and every mistake. This guide walks you through the form line by line, in plain language, the way a 30-year captive manager would explain it across the table.
Here is what you will learn:
- 📋 What an industrial insured captive is and the exact test that decides if you qualify
- 🗂️ Every document and number you must gather before you open the application
- ✍️ A field-by-field walkthrough of the application with sample entries you can copy
- 💵 The fees, capital, and deadlines that govern your filing, with the penalties for missing them
- ⚠️ The mistakes that get applications kicked back, and how to dodge each one
What the Industrial Insured Captive Application Is and Who Must File It
The Industrial Insured Captive application is the formal request that asks Vermont’s Commissioner of Financial Regulation to grant a certificate of authority to a new captive insurer. The form and its attachments live with the Captive Insurance Division in Montpelier, and the legal authority comes from 8 V.S.A. § 6002, the licensing statute. The application is not a contract; it is a license request. No business may write a single policy until the Commissioner signs off.
An “industrial insured captive” is a special category defined in 8 V.S.A. § 6001. It insures the risks of industrial insureds that belong to the same industrial insured group. An industrial insured is a large, professionally managed buyer of insurance, not a small business or an individual consumer. The classic test looks at whether the insured uses a full-time risk manager or buyer, pays a high annual premium, and employs a large workforce.
You must file this application if your group of industrial insureds wants to form its own insurer to cover its own losses. Common filers are a manufacturer with several affiliated plants, a trade group of large contractors, or a healthcare system pooling malpractice risk. The person who signs is usually an officer of the proposed captive or its appointed captive manager. Most applicants hire a licensed captive management firm because Vermont expects a professional manager on day one.
The reason the State cares about your category is simple: it sets your capital floor and your level of scrutiny. An industrial insured captive carries a higher capital requirement than a pure captive because it may insure several related parties rather than one parent. Picking the wrong category on the form changes your minimum capital and can void your filing. Many first-time filers think “captive is captive,” but the label you choose drives the entire review.
Before You Start: Documents and Information You Need
Open the application only after you have built your full packet, because Vermont reviews the form and the attachments together. A captive manager named Dana Reyes keeps a single checklist folder so nothing is missing when the file goes to the Division. Missing items are the number-one cause of delay, and the Division will pause your review until the gap is filled. Gather these before you type a word.
- Proposed captive’s legal name and structure, because the name must be unique and clear the Vermont Secretary of State; a duplicate name forces a refile.
- A business plan / plan of operation, because 8 V.S.A. § 6002 requires it and the whole license rests on it.
- An actuarial feasibility study with five years of loss history and a five-year forecast, because the Division tests whether your premiums can pay your claims.
- Five-year pro forma financial statements, because regulators must see solvency under both expected and adverse loss scenarios.
- NAIC biographical affidavits for every officer and director, because the State screens each person’s character and competence.
- Organizational documents (articles of incorporation or organization, bylaws or operating agreement), because the Division files the signed original with the Secretary of State.
- Parent or member company financial statements, because they prove the group can fund the capital and stand behind the captive.
- Capital and surplus evidence, because you must show at least the statutory minimum is ready in an approved form before you write business.
- Service provider names (captive manager, CPA, actuary, legal counsel, banker), because Vermont reviews and must accept your management team.
- Lines of business and limits, because the form asks exactly what risks you will insure and how much you will keep versus cede.
If any single item is missing, the Division typically issues a deficiency letter and the clock stops. Dana learned to attach the actuarial study and the bios first, since those take the longest to produce.
Where to Get the Form and How to Access It
Vermont does not bury the application behind a paywall; you start through the Captive Insurance Division of the Department of Financial Regulation. Because Vermont runs a high-touch, relationship-based process, most applicants first contact the Division by phone or email to discuss the plan before submitting. The Division’s office is at 89 Main Street, Montpelier, VT 05620, and the captive team can be reached at (802) 828-3304.
The current application package, instructions, and biographical affidavit forms are posted on the Division’s captive pages, and you should always confirm you have the latest revision before filing. Vermont updates its captive law often, including the 2024 amendments under H.659, so a form printed a year ago may be stale. Check the revision date on the packet and match it to the version listed on the Division’s site.
You will also need the NAIC Biographical Affidavit (Form 11), which is a national standard form used across states. It is hosted on the NAIC’s site, not Vermont’s, and it must be notarized. Pull it fresh each time, because the NAIC revises it and an outdated version can be rejected.
Most applicants do not file alone. Vermont’s market includes a deep bench of captive managers, and the Division expects a licensed manager to coordinate the submission. Engaging a manager early means the form arrives complete and in the format reviewers expect, which shortens the back-and-forth.
Step-by-Step: How to Fill Out the Industrial Insured Captive Application Line by Line
The application is organized into identifying fields, business-plan content, financial exhibits, and a sworn signature. Use the exact labels printed on your current packet. Below, each field gets its own walkthrough.
Field 1: Proposed Name of Captive Insurance Company
This field asks for the full legal name your new insurer will use. Type the complete name exactly as it will appear in your articles, including the entity tag such as “Inc.” or “LLC.” For example, Granite Risk Industrial Insured Captive, Inc. goes on the line, not a shorthand like “Granite Captive.” A common edge case is reserving the name with the Secretary of State first so it is not taken between filing and approval.
The most common mistake is using a name that conflicts with an existing Vermont entity, which forces you to refile the organizational documents and delays your certificate. Many filers think the Division reserves the name for them, but it does not; name clearance is your job. Get this right and the rest of your paperwork lines up cleanly.
Field 2: Type of Captive (Category Election)
This field asks which captive category you are applying under, and you select industrial insured captive insurance company. Check that exact box rather than “pure” or “association,” because the category sets your capital floor. For example, Granite Risk checks “industrial insured” because it insures several affiliated manufacturers, not one parent.
The edge case appears when a group looks like both an association and an industrial insured group; you must read § 6001 closely to pick the right label. The common mistake is choosing “pure captive” to grab the lower $250,000 capital floor when the structure is really industrial insured, which the Division catches and rejects. Filers often believe the category is cosmetic, but it directly controls how much money you must post.
Field 3: Principal Place of Business and Registered Agent
This field asks for the captive’s main Vermont address and its registered agent. Enter the Vermont business address, often your captive manager’s office, and name the in-state agent for service of process. For example, Dana Reyes, c/o Summit Captive Management, 100 Bank Street, Burlington, VT 05401 fills the block.
A frequent edge case is using a P.O. Box; the Division wants a physical Vermont address for the principal office. The common mistake is listing an out-of-state parent address, which signals you may not meet Vermont’s home-office expectations and triggers questions. People wrongly assume any mailing address works, but Vermont expects a genuine in-state presence tied to your manager.
Field 4: Names and Biographical Information of Officers and Directors
This field asks you to list every officer and director and attach a notarized NAIC biographical affidavit for each. Write each person’s full legal name and role, then attach the signed affidavit and a third-party background check where required. For example, Marcus Webb, President is listed with his completed Form 11 behind the application.
The edge case is a foreign national director, who may need extra background verification through an approved vendor. The common mistake is submitting an unsigned or un-notarized affidavit, which voids that person’s review and stalls the whole file. Many filers think a résumé can stand in for the affidavit, but only the NAIC form satisfies the requirement.
Field 5: Industrial Insured Qualification Details
This field, unique to your category, asks you to show that each member meets the industrial insured test. For each member, provide the full-time risk manager or insurance buyer’s name and address, the aggregate annual premium, and the number of full-time employees, as Vermont and peer states like Iowa request. For example, Granite Risk lists “Maria Lopez, Risk Manager; aggregate annual premium $1,200,000; 480 full-time employees.”
The edge case is a member that just crossed the employee or premium threshold; document the date and source of your numbers. The common mistake is leaving out the full-time risk manager’s name, which is the heart of the qualification and a near-automatic kickback. Filers often assume size alone qualifies them, but the dedicated risk-management function is what defines an industrial insured.
Field 6: Plan of Operation / Business Plan (Attachment)
This field asks for your detailed plan of operation, attached as an exhibit required by § 6002. Include the business purpose, an organizational chart, the risks insured by line of business, coverages, limits, deductibles, retentions, your reinsurance program, and an investment plan. For example, Granite Risk writes a plan covering general liability and workers’ compensation with a $1,000,000 per-occurrence retention and excess reinsurance above that.
The edge case is using a fronting insurer; you must name the fronting company and explain the arrangement. The common mistake is a vague plan that omits per-loss and aggregate retentions, which forces the actuary and the Division to send the file back. People think the plan is a formality, but it is the document the entire license is built on, and you are bound to it after approval.
Field 7: Financial Projections and Capitalization
This field asks for five-year pro forma financials and proof of your capital and surplus. Attach expected and adverse projections, your maximum probable and maximum possible loss, and evidence that you hold at least the statutory minimum. Under 8 V.S.A. § 6004, an industrial insured captive must hold not less than $500,000 in unimpaired paid-in capital and surplus. For example, Granite Risk shows $650,000 in capital held as cash and an approved letter of credit.
The edge case is funding capital with a letter of credit, which must come from a bank the Commissioner approves. The common mistake is showing only the bare minimum with no cushion, which invites the Commissioner to require more capital under § 6004(b). Filers wrongly assume hitting $500,000 ends the discussion, but the Commissioner can prescribe additional capital based on your risk.
Field 8: Service Providers (Manager, Actuary, CPA, Counsel)
This field asks you to identify your captive manager, actuary, certified public accountant, and legal counsel. Enter each firm’s name and confirm Vermont acceptance, because the State reviews your management team. For example, Summit Captive Management is listed as manager with a named, credentialed actuary attached.
The edge case is using a provider not yet approved in Vermont, which means you may need to submit that firm’s information for review. The common mistake is naming an actuary with no captive experience, which weakens the feasibility study’s credibility. Many filers think any CPA will do, but Vermont expects providers who understand captive accounting and statutory reporting.
Field 9: Certification and Signature
This field is the sworn statement that everything in the application is true. Sign and date as the authorized representative, and have it executed by an officer with authority to bind the captive. For example, Marcus Webb signs as President and dates it 06/02/2026 in MM/DD/YYYY format.
The edge case is a manager signing on the company’s behalf, which requires clear authorization on file. The common mistake is leaving the date blank or signing with an unauthorized person, which makes the certification defective and the filing incomplete. Filers often treat the signature as a rubber stamp, but it is a sworn legal attestation, and false statements carry real consequences.
Three Filled-Out Examples Using Real Scenarios
These three named scenarios show how different groups complete the same application. Each follows one filer through the major fields.
Scenario 1: Granite Risk — a manufacturer with several affiliated plants
| Form Section | What Granite Risk Enters |
|---|---|
| Proposed Name | Granite Risk Industrial Insured Captive, Inc. |
| Type of Captive | Industrial insured captive insurance company |
| Principal Place of Business | 100 Bank Street, Burlington, VT 05401 |
| Officers/Directors | Marcus Webb, President; Dana Reyes, Secretary (NAIC affidavits attached) |
| Industrial Insured Details | Maria Lopez, Risk Manager; $1.2M premium; 480 employees |
| Lines of Business | General liability and workers’ compensation |
| Capital and Surplus | $650,000 (cash plus approved letter of credit) |
| Certification | Signed Marcus Webb, 06/02/2026 |
Scenario 2: Summit Contractors Group — large affiliated construction firms
| Form Section | What Summit Enters |
|---|---|
| Proposed Name | Summit Builders Industrial Insured Captive, Inc. |
| Type of Captive | Industrial insured captive insurance company |
| Principal Place of Business | 25 State Street, Montpelier, VT 05602 |
| Officers/Directors | Aisha Khan, President; Tom Boyle, Treasurer (NAIC affidavits attached) |
| Industrial Insured Details | Each member lists its risk manager, premium, and headcount |
| Lines of Business | Builder’s risk, general liability, equipment |
| Capital and Surplus | $750,000 cash |
| Certification | Signed Aisha Khan, 06/02/2026 |
Scenario 3: Green Mountain Health — a hospital system pooling malpractice risk
| Form Section | What Green Mountain Enters |
|---|---|
| Proposed Name | Green Mountain Health Industrial Insured Captive, Inc. |
| Type of Captive | Industrial insured captive insurance company |
| Principal Place of Business | 400 Maple Avenue, Burlington, VT 05401 |
| Officers/Directors | Dr. Janet Pierce, Chair; Raj Patel, CFO (NAIC affidavits attached) |
| Industrial Insured Details | Janet Pierce, Risk Manager; $4M premium; 2,100 employees |
| Lines of Business | Medical professional liability |
| Capital and Surplus | $1,000,000 (cash plus letter of credit) |
| Certification | Signed Raj Patel, 06/02/2026 |
How to File the Completed Application
Vermont accepts the application directly through its Captive Insurance Division, and most filings travel through your captive manager. Because Vermont runs a personal, communicative process, you typically coordinate the submission format with your assigned reviewer before sending. Keep a complete copy of everything you submit.
- Through your captive manager / Division contact. Your manager submits the full packet to the Division as the reviewers direct; confirm the current preferred method, then keep the dated transmittal as your proof of filing.
- By mail. You may send the package to the Department of Financial Regulation, Captive Insurance Division, 89 Main Street, Montpelier, VT 05620-0501; use a trackable carrier and keep the receipt.
- Original organizational documents. Send wet-ink signed articles, because the Division files the original with the Secretary of State, and a copy will not do.
The application fee is set by 8 V.S.A. § 6002(d), which requires a nonrefundable fee of $500 for each captive insurance company. Historic Division materials also reference a separate license fee and a department-cost charge for external actuarial review, so confirm the exact current amounts and payment method with the Division. Because the fee is nonrefundable, do not pay until your packet is complete. Expected review time runs several weeks and varies with file quality, so build that into your launch date.
What Happens After You File
Once your packet arrives, a Division analyst reviews the application, the business plan, the actuarial study, and the financials together. If something is missing or unclear, the Division sends a deficiency or comment letter, and the review pauses until you respond. Clean files move faster, which is why a complete first submission matters so much.
If the Commissioner is satisfied, the captive receives a certificate of authority under § 6002. At that point you may capitalize the company and begin writing the policies described in your plan. You may not issue any policy or reinsurance contract before the license is granted and capital is in place.
After licensing, the obligations continue. Within 30 days of commencing business, § 6004(d) requires the president and secretary to file a sworn statement certifying the captive held the required capital before it started. The captive must also file annual reports, pay premium taxes, and stick to its approved plan; material changes to the plan need the Commissioner’s prior approval.
Mistakes to Avoid When Filling Out the Application
Each error below has stopped a real filing in its tracks. Read them as a pre-flight check.
- Choosing the wrong captive category, which sets the wrong capital floor and can void the filing.
- Listing capital at exactly the minimum with no cushion, which invites a demand for more capital.
- Omitting a member’s full-time risk manager, which breaks the industrial insured qualification.
- Submitting an unsigned or un-notarized biographical affidavit, which stalls the officer’s review.
- Using a duplicate or unreserved company name, which forces a refile of organizational documents.
- Filing a vague business plan with no retentions or limits, which triggers a deficiency letter.
- Attaching an actuarial study with no five-year history or forecast, which fails the feasibility test.
- Naming an actuary or CPA with no captive experience, which weakens the whole submission.
- Paying the nonrefundable fee before the packet is complete, which wastes money on a rejected file.
- Listing an out-of-state principal address, which raises home-office questions.
- Sending photocopied organizational documents instead of wet-ink originals, which the Division cannot file.
- Forgetting the 30-day post-license capital certification, which puts the new license out of compliance.
Do’s and Don’ts
These quick rules keep your file moving.
- Do reserve your company name first, because a clash forces a refile.
- Do engage a Vermont captive manager early, because the Division expects a professional manager.
- Do match your category to § 6001 exactly, because it controls your capital.
- Do post capital above the $500,000 minimum, because the Commissioner can require more.
- Do keep a dated copy of everything, because it is your proof of filing.
- Do confirm current fees with the Division, because amounts and channels change.
- Don’t issue any policy before licensing, because that breaks the certificate requirement.
- Don’t submit a draft business plan, because the license is built on the final plan.
- Don’t use stale NAIC or application forms, because outdated versions get rejected.
- Don’t skip the risk-manager detail, because it defines the industrial insured test.
- Don’t pay before your packet is complete, because the fee is nonrefundable.
- Don’t ignore the 30-day capital certification, because it keeps your new license valid.
Filing on Your Own vs. With a Captive Manager
Vermont allows professional managers to drive the filing, and the choice shapes your speed and cost.
| Filing Approach | What It Means for You |
|---|---|
| Pros of using a captive manager | Faster, cleaner reviews because the manager knows the format the Division expects |
| Fewer deficiency letters since experienced actuaries and CPAs are already lined up | |
| Ongoing compliance handled, including annual reports and the 30-day capital filing | |
| Direct relationships with Division staff that smooth questions | |
| Strong feasibility studies that survive scrutiny | |
| Cons of using a captive manager | Management fees add ongoing cost |
| Less hands-on control over day-to-day filings | |
| You still must supply accurate underlying data | |
| Pros of filing largely on your own | Lower out-of-pocket cost up front |
| Full control over every document | |
| Cons of filing largely on your own | Higher risk of rejected or delayed filings without captive expertise |
| Vermont expects a professional manager, so a pure DIY path is rare and harder |
FAQs
Do I qualify as an industrial insured if my company is just large?
No. Size alone is not enough. You must show a full-time risk manager or insurance buyer, a high aggregate premium, and a substantial workforce that together meet Vermont’s industrial insured test under § 6001.
Do I pick “pure captive” to lower my capital requirement?
No. You must choose the category that fits your structure. An industrial insured captive requires at least $500,000 in capital, and mislabeling to grab a lower floor will be caught and rejected.
Do I write the full legal name in the name field?
Yes. Enter the complete legal name with its entity tag, such as Granite Risk Industrial Insured Captive, Inc., exactly as it appears on your articles, and clear it with the Secretary of State first.
Do I list each member’s risk manager in the qualification section?
Yes. For every member you must provide the full-time risk manager or buyer’s name and address, the aggregate annual premium, and the full-time employee count. Leaving the risk manager out breaks the qualification.
Do I need a notarized biographical affidavit for every officer?
Yes. Each officer and director needs a signed, notarized NAIC Form 11 affidavit. A résumé cannot replace it, and an unsigned affidavit stalls that person’s review.
Do I have to use the NAIC Form 11 affidavit specifically?
Yes. Vermont, like peer states, relies on the standardized NAIC biographical affidavit. Pull a fresh copy each time, because the NAIC revises it and outdated versions can be rejected.
Do I file the actual signed articles or a copy?
Yes, you file wet-ink originals. The Division files your signed organizational documents with the Secretary of State, so photocopies are not accepted for that purpose.
Do I need an actuarial feasibility study?
Yes. You must attach a study with at least five years of loss history and a five-year forecast. The Division uses it to test whether your premiums can cover your projected claims.
Do I have to hold more than the $500,000 minimum capital?
No, not always, but the Commissioner may require more. Under § 6004(b), the State can prescribe additional capital based on the type, volume, and nature of your risk.
Do I pay the application fee when I send the form?
Yes, but only once your packet is complete. The § 6002 fee of $500 is nonrefundable, so paying on an incomplete file simply wastes the money if it is returned.
Do I file anything after the license is granted?
Yes. Within 30 days of commencing business, your president and secretary must file a sworn statement certifying the captive held the required capital before it started writing business.
Do I write the date as MM/DD/YYYY on the signature line?
Yes. Use the MM/DD/YYYY format, such as 06/02/2026, and have an authorized officer sign. A blank date or an unauthorized signer makes the certification defective.
Do I need a Vermont address for the principal place of business?
Yes. Vermont expects a physical in-state address, usually your captive manager’s office, rather than a P.O. Box or an out-of-state parent address.
Do I have to use a captive manager to file?
No, it is not strictly mandatory, but Vermont expects a professional manager and the process strongly favors one. Most successful applicants engage a licensed Vermont captive manager.
Related reading
- How to Fill Out the Massachusetts Captive Insurance Company Application + FAQs
- How to Fill Out the Captive Actuarial Opinion Filing (w/ Examples) + FAQs
- How to Fill Out the DC Captive Insurance Company Application + FAQs
- How to Fill Out the Montana Captive Insurance Company Application + FAQs
- How to Fill Out the South Carolina Captive Insurance Application + FAQs
- How to Fill Out the Vermont Captive Insurance Company Application + FAQs