How to Fill Out the Washington OIC Captive Insurance Application (Eligible Captive Insurer Registration) + FAQs

The Washington Office of the Insurance Commissioner (OIC) Captive Insurance Application is the registration filing that every out-of-state captive insurer must submit when it covers risks for a Washington-based parent or affiliate. You file it under chapter 48.201 RCW and the rules in chapter 284-201 WAC, which the OIC adopted on November 15, 2021. Washington does not license or form captives. Instead, it registers captives that are domiciled elsewhere and that insure Washington entities, then taxes the Washington share of their premiums.

This matters because a captive that skips registration is treated as an unlawful, unauthorized insurer under WAC 284-201-250, which opens the door to fines, back taxes, penalties, and interest. The clock is short, too: you have only 120 days from your first Washington-risk policy to register. Washington’s law reaches back to January 1, 2011, so a single registration can trigger more than a decade of premium tax review, which is why so many captive managers treat this filing with care.

In this guide, you will learn:

  • 📋 What the OIC captive registration is, who must file it, and the exact statute behind it
  • 🗂️ Every document and number you must gather before you start
  • ✍️ A line-by-line walkthrough of each part of the registration package
  • 👥 Three full examples that follow real captives through the whole filing
  • 💰 How the 2% premium tax, the $2,500 fee, and the 2011 lookback work
  • ⚠️ The mistakes that cause denials, late penalties, and unauthorized-insurer status

What the OIC Captive Registration Is and Who Must File It

The OIC captive registration is a formal application that an out-of-state captive insurer submits to the Washington Insurance Commissioner to gain legal recognition while it insures Washington risks. The Legislature created it through Senate Bill 5315 in 2021, and it lives in chapter 48.201 RCW. The plain-English point is simple: if your captive insures a company whose nerve center sits in Washington, the state wants you on its books and wants its share of the premium tax. The consequence of ignoring this is steep, because the OIC can treat an unregistered captive as an illegal insurer and pursue back taxes to 2011.

You must file if your captive meets the five-part test for an “eligible captive insurer” in RCW 48.201.020. The captive must be owned by or contractually tied to a captive owner, insure that owner or its affiliates, have at least one insured whose principal place of business is in Washington, hold assets that exceed liabilities by at least $1,000,000 as shown by audited financials, and be licensed as a captive in its home state. A captive owner means an entity organized under Title 23B, 24, or 25 RCW (or a like law elsewhere), a public institution of higher education, or a municipal corporation under Title 54 RCW.

Some captives are carved out. Risk retention groups that register under chapter 48.92 RCW and captives that place all their coverage through a surplus line broker under chapter 48.15 RCW do not register here, per WAC 284-201-120. A common misconception is that forming the captive in Vermont, Utah, or the Cayman Islands keeps it outside Washington’s reach. That belief is wrong and costly, because the trigger is the location of the insured’s nerve center, not where the captive sits.

Before You Start: Documents and Information You Need

Gather your package first, because the OIC can request more and can deny a registration that arrives thin under WAC 284-201-210. A clean package speeds approval and avoids a back-and-forth that can push you past a tax deadline. Here is your pre-filing checklist:

  • Audited financial statements prepared by an independent certified public accountant. These prove the $1,000,000 surplus and the ability to pay debts; without them, the OIC cannot approve you.
  • Certificate of good standing from your domicile regulator. This shows you are a licensed captive in your home jurisdiction; a missing one stalls the whole filing.
  • Your captive’s license number and domicile (for example, Vermont or Utah). The OIC checks this against your home regulator’s records.
  • Legal name and formation details of the captive owner. The owner must qualify under Title 23B, 24, 25, or 54 RCW, or be a public institution of higher education.
  • List of insureds and their principal places of business. This proves the Washington nerve-center link that triggers registration.
  • First Washington-risk policy effective date. This sets your 120-day deadline; guess wrong and you may already be late.
  • Premium history back to January 1, 2011 for Washington risks. The 10-year lookback means old years still matter for tax.
  • Your Washington-risk allocation methodology. You must explain how you split premium into Washington’s share using a reasonable method.
  • A tax contact name, email, and phone. The OIC emails tax-form instructions to this contact each January, so a stale contact means a missed tax notice.
  • $2,500 registration fee and an accepted payment method. No fee, no approval.

A missing audited statement is the single most common reason a package stalls, because RCW 48.201.030 makes that statement the proof of solvency. If your fiscal year just closed and the audit is not done, contact the OIC early rather than filing an incomplete package.

Where to Get the Form and How to Access It

Washington does not post a single numbered fillable PDF the way captive-domicile states do. Instead, the registration is a document package you submit to the OIC, and the agency provides instructions and any current intake forms through its insurer pages. Start at the OIC’s filing instructions page and contact the agency to confirm the current intake method before you send anything. The governing rules you should read first are WAC 284-201-210 for registration and WAC 284-201-220 for renewal.

The OIC’s Rates and Forms Help Desk is the front door for questions about how to submit. You can reach it by email at RFHelpdesk@oic.wa.gov or by phone at 360-725-7111, as listed on the NAIC Washington contact page. Ask them to confirm the current registration intake channel, the accepted file formats for your audited statements, and how to pay the $2,500 fee. This call protects you, because an outdated form or a wrong email can delay approval past a tax due date.

Confirm the rule version before you rely on any instruction. The captive rules carry a last-update stamp of November 15, 2021 in chapter 284-201 WAC, and the OIC published clarifying updates in 2026, so check that you are reading the current text. A misconception here is that a downloaded copy from a law-aggregator site is always current. Aggregators can lag, so the official Washington Legislature page is your safest source for the live rule.

Step-by-Step: How to Fill Out the Washington Eligible Captive Insurer Registration Line by Line

The registration package breaks into logical parts. Complete each one in order, use your captive’s exact legal name throughout, and keep every entry consistent with your audited financials and your domicile records.

Part 1: Captive Insurer Legal Name and Domicile

This field asks for the full legal name of the captive insurer and the state or country where it is licensed. Enter the name exactly as it appears on your domicile license and your audited financial statements, in all capital letters if the form uses them, with no abbreviations the regulator did not use. For example, EVERGREEN RISK INSURANCE COMPANY, INC. domiciled in VERMONT is how a captive owned by a Seattle manufacturer would enter it. If your captive recently changed its name or redomiciled, use the current legal name and be ready to attach the amendment paperwork.

A common mistake is entering a “doing business as” name or a shortened brand name instead of the chartered legal name, which causes a mismatch when the OIC cross-checks your domicile regulator. That mismatch can hold up your whole approval. A frequent misconception is that the captive’s name does not matter much because the OIC mainly cares about the parent. The opposite is true, because registration attaches to the captive insurer itself as the registered eligible captive insurer under WAC 284-201-130.

Part 2: Domicile License Number and Good Standing

This field asks for your captive’s license or certificate number in its home jurisdiction and proof that you are in good standing. Enter the license number exactly as printed on your domicile certificate, and attach a current certificate of good standing dated close to your filing date. For example, Cascade Mutual Captive, Ltd. would enter its Utah captive certificate number and attach a Utah Insurance Department good-standing letter dated within the last 90 days. If your domicile issues good-standing letters only on request, order it early because some regulators take weeks.

A common mistake is attaching an old good-standing letter from a prior renewal cycle, which the OIC may reject as stale, delaying approval past a deadline. The direct consequence is that your registration period, which runs from approval through June 30 under WAC 284-201-210, starts later than you planned. A misconception is that a home-state license alone proves good standing. It does not, because a license can exist while a captive is under supervision or behind on filings, so the OIC wants a current standing letter.

Part 3: Captive Owner Identification and Eligibility

This field asks who owns or controls the captive and how that owner qualifies under Washington law. Enter the captive owner’s full legal name, its form of organization, and the statute it falls under, such as Title 23B RCW for a business corporation or “public institution of higher education.” For example, a captive owned by Rainier Health System would name the health system and state that it is a Washington nonprofit under Title 24 RCW. If ownership is split among several affiliates, list each owner and its percentage, because the definition of captive owner in RCW 48.201.020 allows partial ownership or a contractual member relationship.

A common mistake is naming an owner that does not fit any qualifying category, which makes the captive ineligible and leads to denial. The consequence is that the captive remains an unlawful unauthorized insurer until it fixes its structure or proves a qualifying owner. A misconception is that any company with a Washington office counts as a captive owner. The law is narrower, because it lists specific organizational titles, plus higher-education institutions and Title 54 municipal corporations.

Part 4: Insureds and Principal Place of Business

This field asks you to identify the insureds and show that at least one has its principal place of business in Washington. List each insured’s legal name and the city and state of its nerve center, which WAC 284-201-130 defines as the headquarters where management directs and controls the business. For example, Olympic Foods LLC, headquartered in Tacoma, WA, would be listed as the Washington insured even if its captive parent sits in Delaware. Analyze each subsidiary on its own, because a subsidiary headquartered in Washington creates the link even when the parent is elsewhere.

A common mistake is listing the parent’s mailing address instead of the true nerve center, which can either falsely trigger or falsely avoid registration and invite a later dispute. The consequence of getting this wrong is back taxes and unauthorized-insurer exposure if the OIC finds a Washington insured you left off. A misconception is that a small sales office in Washington makes the state the principal place of business. It usually does not, because the nerve-center test points to headquarters-level direction, not a branch.

Part 5: Financial Eligibility (Audited Surplus of $1,000,000)

This field asks you to prove that assets exceed liabilities by at least $1,000,000 and that the captive can pay debts as they come due. Attach audited financial statements prepared by an independent certified public accountant, and point to the line that shows surplus above $1,000,000, as RCW 48.201.030 requires. For example, Evergreen Risk Insurance Company would attach its CPA-audited year-end statements showing $3.4 million in net assets. If your audit is not final, ask the OIC how to proceed rather than sending unaudited or internal numbers.

A common mistake is submitting management-prepared or unaudited statements, which do not satisfy the statute and lead to denial. The consequence is a rejected package and a restart, which can push approval past your March 1 tax obligations. A misconception is that strong cash balances or a parent guarantee can substitute for audited surplus. They cannot, because the law names audited financial statements by an independent CPA as the only accepted proof.

Part 6: Washington Risk Allocation Methodology

This field asks how you separate Washington’s share of premium from your total book. Describe your reasonable allocation method and attach the supporting analysis, since RCW 48.201.040 lets you use actuarial analysis or a proxy such as sales, property value, or payroll. For example, Cascade Mutual Captive might allocate 18% of premium to Washington based on the share of insured property located in the state. Document the math clearly, because the OIC wants your methodology and analysis filed by April 1 under WAC 284-201-240.

A common mistake is choosing a method that hides Washington exposure, such as allocating by where premium is paid, which the law expressly rejects. The consequence is a recalculated tax plus penalties and interest for periods after July 1, 2021. A misconception is that the captive can pick a brand-new method each year to lower the bill. Consistency matters, because the OIC reviews your methodology and can challenge an allocation that shifts only to cut tax.

Part 7: Premium History Since January 1, 2011

This field asks for written-premium figures for Washington risks for each year back to January 1, 2011, if not already remitted. Report premiums on a written basis, as WAC 284-201-240 directs, and separate the Washington share using your allocation method. For example, a captive that began covering a Spokane affiliate in 2015 would report Washington written premium for 2015 through the current year. Pull this from your historical books early, because reconstructing a decade of premium takes time.

A common mistake is reporting only recent years and ignoring the lookback, which leaves a tax gap the OIC can assess later. The consequence is a surprise bill for old years, though periods before January 1, 2021 escape penalties and interest under the rule. A misconception is that the lookback applies only to property and casualty lines. It is broader, because eligible captives owe tax on Washington risks for all coverage types provided after January 1, 2011, even lines they can no longer write going forward.

Part 8: Tax Contact and Registration Fee

This field asks for your tax contact details and confirmation of the $2,500 fee. Enter a current name, email, and phone for the person who should receive tax-form instructions, because the OIC emails those instructions each January under WAC 284-201-240. For example, Maria Chen, Captive Manager, mchen@evergreenrisk.com, 802-555-0147 would be the listed contact, paired with the $2,500 registration fee. Confirm the accepted payment method with the OIC before sending.

A common mistake is listing a contact who later leaves the firm, which means the January tax notice goes to a dead inbox and the March 1 deadline slips by unnoticed. The consequence is a late tax with penalties and interest. A misconception is that the $2,500 is an annual tax. It is a registration fee, separate from the 2% premium tax, and the renewal fee is set yearly at up to $2,500 under WAC 284-201-220.

Part 9: Coverage Lines and Limitations Attestation

This field asks you to confirm that your Washington coverage stays within the lines the law allows. Attest that for Washington risks you provide only property and casualty insurance to the captive owner or its affiliates, as WAC 284-201-230 requires. For example, Olympic Foods’ captive would confirm it writes property and general liability for the parent and affiliates only. If you also act as a reinsurer, note that, because the limitation does not apply to assumed reinsurance.

A common mistake is listing prohibited lines such as stop-loss insurance, which WAC 284-201-230 bars for Washington risks. The consequence is a coverage that may be deemed unauthorized, with enforcement exposure. A misconception is that a captive can directly cover workers’ compensation for Washington workers. It cannot under Title 51 RCW, though it may indemnify a self-insured employer for that liability.

Part 10: Authorized Signature and Certification

This field asks an authorized officer to sign and certify that everything in the package is true. Sign with the full legal name and title of an officer who can bind the captive, and date it in MM/DD/YYYY format. For example, David Okafor, President, signs and dates 06/15/2026. If an outside captive manager prepares the package, an officer of the captive, not just the manager, should sign the certification.

A common mistake is letting an unauthorized staff member sign, which can void the certification and force a refile. The consequence is delay and a later registration start date. A misconception is that an electronic typed name is never valid. Many filings accept e-signatures, but you should confirm the OIC’s accepted signature format before you submit.

Three Filled-Out Examples Using Real Scenarios

These three scenarios show how different captives move through the registration from start to finish. Each follows one named filer and shows what goes in the main parts of the package.

Scenario 1: Single-parent captive of a Washington manufacturer. David Okafor manages Evergreen Risk Insurance Company, a Vermont captive owned by a Seattle equipment maker.

Form Section What Evergreen Enters
Part 1: Captive name and domicile EVERGREEN RISK INSURANCE COMPANY, INC., domiciled in Vermont
Part 2: License and good standing Vermont captive certificate number plus a good-standing letter dated 05/20/2026
Part 3: Captive owner Seattle manufacturer organized under Title 23B RCW
Part 4: Insureds Manufacturer headquartered in Seattle, WA (Washington nerve center)
Part 5: Financial eligibility CPA-audited statements showing $3.4 million net assets
Part 6: Allocation method 100% Washington, single Washington insured
Part 7: Premium history Washington written premium from 2018 to present
Part 8: Tax contact and fee Maria Chen, mchen@evergreenrisk.com, plus $2,500 fee
Part 9: Coverage lines Property and general liability only
Part 10: Signature David Okafor, President, 06/15/2026

Scenario 2: Multi-state group captive with partial Washington risk. Priya Nair runs Cascade Mutual Captive, Ltd., a Utah group captive whose members operate in five states.

Form Section What Cascade Mutual Enters
Part 1: Captive name and domicile CASCADE MUTUAL CAPTIVE, LTD., domiciled in Utah
Part 2: License and good standing Utah certificate number plus a current good-standing letter
Part 3: Captive owner Member companies organized under Title 25 RCW and like laws
Part 4: Insureds One member headquartered in Spokane, WA
Part 5: Financial eligibility CPA-audited statements showing $12 million net assets
Part 6: Allocation method 18% of premium by Washington property value
Part 7: Premium history Washington written premium from 2015 to present
Part 8: Tax contact and fee Priya Nair, pnair@cascademutual.com, plus $2,500 fee
Part 9: Coverage lines Property and casualty for members only
Part 10: Signature Priya Nair, CFO, 06/22/2026

Scenario 3: Captive affiliated with a public university (tax-exempt on premium). James Whitfield administers a captive owned by a Washington public university.

Form Section What the University Captive Enters
Part 1: Captive name and domicile University captive legal name, domiciled in Hawaii
Part 2: License and good standing Hawaii captive license number plus good-standing letter
Part 3: Captive owner Public institution of higher education under RCW 28B.10.016
Part 4: Insureds University headquartered in Washington
Part 5: Financial eligibility CPA-audited statements showing $8 million net assets
Part 6: Allocation method Allocation by Washington campus payroll
Part 7: Premium history Washington written premium from 2012 to present
Part 8: Tax contact and fee James Whitfield, jwhitfield@univ.edu, plus $2,500 fee
Part 9: Coverage lines Property and casualty for the university and affiliates
Part 10: Signature James Whitfield, Director of Risk, 06/10/2026

The university captive still registers and pays the $2,500 fee, but it owes no 2% premium tax. That exemption comes straight from RCW 48.201.040, which shields captives affiliated with a public institution of higher education from the premium tax.

How to File the Completed Registration

Washington’s captive registration is a document submission to the OIC rather than a public web portal, so confirm the current channel with the agency before you send. Use the OIC’s filing instructions page and the Rates and Forms Help Desk to verify the exact intake method, accepted file formats, and fee payment process. Here is how each available channel works in practice.

  • Email submission to the OIC. Send your package and audited statements to the OIC after confirming the correct intake address with the Help Desk at RFHelpdesk@oic.wa.gov or 360-725-7111. Keep the sent email and any confirmation reply as your proof of filing. Processing depends on completeness, so a clean package moves faster.
  • Mail or in person. If the OIC directs you to mail or hand-deliver documents, send them to the Office of the Insurance Commissioner in Olympia, Washington, and use certified mail so you have a delivery receipt. Confirm the current mailing address with the Help Desk, because OIC has separate mail stops for different functions.
  • Fee payment. The registration fee is $2,500, set by WAC 284-201-210. Confirm accepted payment methods, such as check or electronic payment, when you confirm the intake channel, and keep the payment record as part of your proof of filing.

Your registration period runs from the date the OIC approves it through June 30, under WAC 284-201-210. For renewal, file by April 1 so the OIC can approve before the June 30 expiration, because a lapse forces a brand-new application and a new fee under WAC 284-201-220. Keep copies of everything you send, because proof of timely filing protects you if a deadline dispute arises.

What Happens After You File

After you submit, the OIC reviews your package to confirm the $1,000,000 audited surplus, good standing in your domicile, and a qualifying captive owner. The commissioner may request more documentation under WAC 284-201-210, and you must provide it, or the registration can be denied. If approved, you become a registered eligible captive insurer with a registration period running through June 30. If denied, you may demand an adjudicative hearing under WAC 284-201-300.

Once registered, your tax duties begin. Each January, the OIC emails tax-form instructions to your listed tax contact, and you must file a written-basis statement of premiums and pay the 2% tax by March 1, under WAC 284-201-240. You must also submit your Washington-risk allocation methodology by April 1. Miss the tax due date and you face penalties and interest under RCW 48.14.060, so calendar these dates the moment you register.

The lookback still applies after approval. Premiums for Washington risks back to January 1, 2011 remain due if not already paid, though periods before January 1, 2021 are spared penalties and interest under WAC 284-201-240. The OIC can audit your allocation and your history, so keep your workpapers ready. A registered captive that later violates the chapter risks suspension, revocation, or refusal to renew under WAC 284-201-250.

Mistakes to Avoid When Filling Out the Registration

Each of these errors maps to a specific field or duty, and each carries a direct cost. Read this list against your own package before you file.

  • Filing after the 120-day window. You become an unlawful unauthorized insurer exposed to fines and back taxes.
  • Submitting unaudited financials. The OIC cannot verify the $1,000,000 surplus and will deny the registration.
  • Using a stale good-standing letter. The OIC may reject it and your registration start date slips.
  • Naming a non-qualifying captive owner. The captive is ineligible and the filing is denied.
  • Listing a branch office as the principal place of business. You misjudge the Washington link and invite a later dispute.
  • Choosing an allocation method based on where premium is paid. The law rejects it and recalculates your tax.
  • Reporting only recent premium years. You leave a lookback gap the OIC can assess to 2011.
  • Forgetting the tax contact update. The January tax notice goes to a dead inbox and March 1 passes.
  • Treating the $2,500 fee as the full tax. You underpay and owe the 2% premium tax on top.
  • Listing prohibited lines such as stop-loss. The coverage may be deemed unauthorized.
  • Trying to directly cover Washington workers’ compensation. Title 51 RCW bars it, and only indemnity of a self-insured employer is allowed.
  • Letting an unauthorized person sign the certification. The package can be voided and refiled.

Do’s and Don’ts

  • Do confirm the current intake channel with the OIC Help Desk before sending anything, so your package does not bounce.
  • Do attach CPA-audited statements, because they are the only accepted proof of surplus.
  • Do order your good-standing letter early, since some regulators take weeks.
  • Do document your allocation method clearly, because the OIC reviews it and can challenge weak math.
  • Do calendar March 1 and April 1, since the tax and methodology deadlines are firm.
  • Do keep proof of filing and payment, because it protects you in any deadline dispute.
  • Don’t assume an out-of-state domicile shields you, because the trigger is the insured’s Washington nerve center.
  • Don’t use a “doing business as” name, since a mismatch holds up cross-checks.
  • Don’t ignore the 2011 lookback, because old premium years still carry tax.
  • Don’t pick an allocation method just to lower the bill, since shifting methods invite challenge.
  • Don’t list prohibited lines, because that can make coverage unauthorized.
  • Don’t let your registration lapse, since a lapse forces a new application and a new fee.

Pros and Cons of Registering on Your Own vs. With a Captive Manager or Attorney

Self-Filing Filing With a Captive Manager or Attorney
Lower upfront cost, because you avoid professional fees Higher cost, but the fee often offsets penalty exposure
Full control over your timeline and documents Less day-to-day control, though experts keep deadlines on track
Direct knowledge of your own premium history Faster reconstruction of a decade of premium by specialists
Works well for a simple single-parent captive Better for multi-state allocation that needs actuarial support
Risk of missing the nerve-center or lookback rules Lower risk of eligibility and allocation errors
You handle any OIC document requests alone Professionals manage OIC requests and any hearing under WAC 284-201-300

A single-parent captive with one Washington insured and clean audited statements is often a sound self-file. A multi-state group captive with a complex allocation, or any captive facing a large 2011-to-present lookback, usually benefits from professional help, because the cost of an allocation error or a missed deadline can dwarf the fee.

FAQs

Do I have to register if my captive is domiciled in Vermont, not Washington?

Yes. Domicile does not matter if one insured’s principal place of business is in Washington. The trigger under RCW 48.201.020 is the Washington nerve center, not where the captive was formed.

Do I owe Washington premium tax if my captive is owned by a public university?

No. Captives affiliated with a public institution of higher education are exempt from the 2% premium tax under RCW 48.201.040, though they still register and pay the $2,500 fee.

Do I list my parent’s address or the insured subsidiary’s headquarters in the insureds section?

No. Do not default to the parent. List each insured’s own principal place of business, because WAC 284-201-130 analyzes a subsidiary’s nerve center separately from its parent.

Do I write a “doing business as” name in the captive name field?

No. Use the captive’s exact chartered legal name from your domicile license, because a DBA or brand name causes a mismatch when the OIC cross-checks your home regulator.

Do unaudited financial statements satisfy the $1,000,000 surplus proof?

No. Only audited statements by an independent CPA count under RCW 48.201.030. Management-prepared numbers will lead to denial.

Do I report premium on a written or paid basis in the premium history section?

Yes, on a written basis. WAC 284-201-240 directs that reporting of premiums be on a written basis, not a paid or earned basis.

Do I have to pay tax for years before I registered?

Yes. Premiums for Washington risks back to January 1, 2011 are due if not already paid, though periods before January 1, 2021 escape penalties and interest under WAC 284-201-240.

Do I have a hard deadline to register after my first Washington policy?

Yes. You must register within 120 days of first issuing a policy covering Washington risks, under RCW 48.201.030. Missing it makes you an unauthorized insurer.

Do I file the renewal by June 30 or earlier?

Yes, earlier. File the renewal by April 1 so the OIC can approve before the June 30 expiration, because a lapse forces a brand-new application under WAC 284-201-220.

Do I have to pay the 2% tax separately from the $2,500 fee?

Yes. The $2,500 is a registration fee. The 2% premium tax on Washington risks is a separate yearly obligation due by March 1 under RCW 48.201.040.

Do I have to register if I place all my coverage through a surplus line broker?

No. Captives that place insurance solely through a surplus line broker under chapter 48.15 RCW are outside this chapter per WAC 284-201-120.

Do I have to submit my Washington-risk allocation method to the OIC?

Yes. You must share your methodology and analysis with the commissioner by April 1 each year under WAC 284-201-240, and use a reasonable, consistent method.

Do I get a hearing if the OIC denies my registration?

Yes. You may demand an adjudicative proceeding under WAC 284-201-300 and chapters 48.04 and 34.05 RCW if the commissioner denies or refuses to renew your registration.

Do I list a captive manager as the signer on the certification?

No. An authorized officer of the captive should sign and certify the package, because the certification binds the captive insurer, not just its outside manager.