Life insurance when you move abroad: is your policy still valid?

Start with the rule almost nothing written for consumers mentions. Where the parties to an insurance contract have chosen no governing law — and most retail policyholders have never been asked to choose one — Rome I provides that the contract is governed by the law of the Member State in which the risk was situated at the time of conclusion of the contract. For life assurance the risk sits where the policyholder habitually resided when the contract was made. Solvency II locates the "commitment" the same way.

Read the words carefully, because the tense is the whole finding. Not where the risk is now. Where it was when you signed. A move does not, by itself, shift the governing law of a policy you already hold, and it cuts both ways: your contract is not quietly reissued under the rules of your new country, and it is not quietly improved by them either. Two caveats belong beside that rather than buried under it — the parties can always agree to change the applicable law afterwards, and Rome I is a conflict-of-laws instrument, not a licensing one.

Which is the second half of the finding, and the half people miss. Whether the contract is valid and whether the insurer may still service it are different questions with different answers. If an insurer loses the right to operate where you now live, the contract does not evaporate — run-off regimes exist precisely so that it can go on being performed. What stops is everything forward-looking. EIOPA told supervisors to prevent affected insurers concluding new contracts or to "establish, renew, extend, increase or resume insurance cover under the existing insurance contracts". The UK's statutory equivalent permits only activity "necessary for the performance of a pre-existing contract", plus transfer of the book to an authorised firm, and it runs for a maximum of fifteen years for insurance contracts.

So the practical shape of it is an asymmetry. Your existing sum assured is safe to claim on. Any increase, extension or new option is not available. That is the single strongest argument for sizing cover before a move rather than after it — not because the move endangers what you hold, but because it can quietly close the door on adding to it.

And here is the claim this page is refusing to repeat. Nothing we read makes a domestic policy void on emigration. No wording in front of us says a policy lapses because you left. Legal & General's terms contain no residence condition after inception at all, and the only lapse trigger stated anywhere in that document is non-payment. The idea that emigrating kills your life cover is in wide circulation and it is not in the contracts. What is in the contracts is stranger and more useful, and the next two sections are about that.

Death in service is the most widely held life cover in this readership and the least examined, because it arrives with the job rather than being bought. It is real cover and it is worth counting. It is also cover you rent from an employer, and it ends when the arrangement does. MetLife's registered group life terms are typical: cover "will terminate automatically with immediate effect" when the member ceases to be an employee, ceases to be eligible, reaches termination age or dies.

Two further edges matter specifically to people who move. Canada Life and Aviva both make residence an independent cessation trigger — cover ends on ceasing to reside or work in an agreed country, or on moving to a location outside the scheme's territories. So a member relocated between two offices of the same employer can lose the benefit without ever leaving the employer, and without anything happening that looks like a change in employment.

For decades the softening mechanism was the continuation option: leave the scheme, take the cover on at your own expense, no fresh medical evidence. That is what people are quietly relying on when they treat death in service as a foundation rather than a top-up. On the current paper it has largely stopped existing. Legal & General's group protection technical guide answers it in a single line — "No, a member cannot continue cover at their own expense if they stop working for you." MetLife and Generali state the same. Aviva's is closed to new policies. Three insurers now devote a numbered clause to saying no.

We looked for the counter-example rather than assuming there was none, and found one: an Irish arrangement whose published specimen dates from 2012 — thirty-one days to exercise, under 50, no medical evidence, capped at the lower of four times salary and EUR 1.5m, at individual rates. One specimen, fourteen years old, in another market. That is not a mechanism to build a household plan on.

The consequence is a sequencing rule rather than a purchase. If group cover is carrying a mortgage or a family, the personal policy behind it has to be arranged while you are still employed and still insurable — before the resignation, not after it, because after it you are applying with whatever health and whatever address you have on that day. Group cover is worth having and worth counting. It is not worth planning around.

Almost everything written about life cover and mobility is about what happens to a policy you hold. The tighter constraint sits earlier: whether anyone will write you a new one from where you now live. Domestic insurers put residence in the eligibility clause rather than in the cover. Legal & General require a UK resident who has lived in the UK at least 183 days in the last tax year. Aviva require your main home to be in the UK, Channel Islands, Isle of Man or Gibraltar, with "no current intention of moving anywhere else permanently" — a condition about your plans, not your address.

International insurers publish country lists instead. Friends Provident International's underwriting guide accepts residents of Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the UAE, excludes Omani, Qatari and Saudi nationals from full cover, and adds that where the life assured "intends to change their permanent country of residence in the near future, we may not be able to offer terms". Nationality, residence and your own stated intentions all sit inside the underwriting decision. Health is only part of it.

Which brings us to the word the category leans on hardest, and the second claim this page declines to repeat. Portable is written in brochures far more often than it is written in contracts. We checked it against the documents. Friends Provident International's product guide says the plan is "wholly portable" — but that is pre-sale literature, the policy conditions it defers to are not published, and their own underwriting guide contains the sentence quoted above. RL360's LifePlan terms never use the word worldwide and contain no territorial-scope clause at all; the "200 countries worldwide" panel in the product guide describes a customer base, not a scope of cover. Zurich International's conditions reserve a right to modify without your consent or to terminate.

An international policy may well travel better than a domestic one. Several are built for exactly that. But it is not promised in writing anything like as often as it is promised in conversation, and a page that repeated the brochure line would be doing the thing this practice exists to stop. Ask for the policy conditions rather than the product guide, and read the clause rather than the adjective.

The policy names a beneficiary. Succession law and tax law then decide what reaches them, and both follow people rather than paper — which is what makes this the section that changes most when a household moves.

Succession first. Under the EU succession regulation the law of your habitual residence at death governs the succession as a whole, unless you have chosen the law of your nationality. Insurance contracts sit outside that regulation's scope — but expressly "without prejudice" to the rule that succession law still governs reserved shares and any obligation to restore or account for gifts. Which means the exclusion is narrower than it first reads, and the country you die habitually resident in still has something to say about a nomination made years earlier somewhere else.

Three worked examples, each read from the instrument rather than from a summary, and each scoped to its own jurisdiction because there is no general rule here to scope them to. In Switzerland the beneficiary takes directly and outside the estate — but the ZGB adds the surrender value of the claim back into the estate for the reserved-share calculation and makes it subject to reduction (Arts. 476 and 529). In France the capital "ne fait pas partie de la succession" and is subject neither to rapport nor to réduction, unless the premiums were "manifestement exagérées" against the policyholder's means. InEngland and Wales there is no forced heirship at all, and a policy written under s. 11 of the Married Women's Property Act 1882 creates a trust whose proceeds "shall not … form part of the estate of the insured".

Notice what all three claw back where they claw back anything: the premiums or the surrender value, not the death benefit. That is a genuinely useful pattern, and it is the closest thing to a general observation this section will make.

Tax is where a wrong sentence does real damage, so read the next paragraphs as three examples rather than as a rule. There is no "usually" available here.

France levies a charge on death benefits funded by premiums paid before the insured turned 70: an allowance of €152,500 per beneficiary, then 20% up to €700,000 of the taxable share and 31.25% above it, under CGI art. 990 I. The trigger is residence — the levy bites where the beneficiary is fiscally domiciled in France at the death and has been for at least six of the previous ten years, or where the insured is fiscally domiciled in France at death. Read that first limb twice. It means naming a child who lives in Paris can pull a policy into French tax that has no other connection to France whatsoever: not the insurer, not the policyholder, not the money. Premiums paid after 70 sit under a different article, art. 757 B, with a single €30,500 allowance shared across all beneficiaries and all contracts.

The United Kingdom. Proceeds are generally free of income tax and capital gains tax, but form part of the estate for inheritance tax, because the estate is "the aggregate of all the property to which he is beneficially entitled". That definition is precisely why policies are written in trust — and why HMRC then looks at the premiums as transfers of value instead. Since 6 April 2025 UK inheritance tax turns on long-term residence rather than on domicile: UK resident for at least 10 of the previous 20 tax years, with a sliding scale for shedding the status.

The United States. The death benefit is excluded from gross income, but is included in the gross estate where the deceased held incidents of ownership. And one provision most people have never heard of: insurance on the life of "a nonresident not a citizen of the United States" is deemed not to be property within the United States for estate-tax purposes. While we are here, a correction worth making because the figure is repeated everywhere — the "$60,000 exemption" for non-resident aliens is not a statutory exemption at all. It is the IRS filing threshold. The statute, 26 U.S.C. § 2102(b)(1), gives a credit of USD 13,000, and treaties can displace both. We read that on law.cornell.edu because uscode.house.gov was unreachable from here, and we would rather say so than imply a source we did not open.

We are advisers, not tax advisers, and none of the above is advice on your position. What a review does is make sure the question gets asked in the right jurisdiction — which is usually the beneficiary's, not yours — before the policy is written rather than after it is claimed.

Every other page in this category will tell you all four. We read for them, could not support them, and would rather print the gap than fill it — so here is what came out, and why.

1. That a domestic policy is void or lapses when you emigrate.No wording we read says this. Legal & General's terms contain no residence condition after inception at all, and the only lapse trigger stated in that document is non-payment. Royal London's narrowest-consequence wording says only that leaving the UK permanently "could mean that you can't make changes to this policy" — no cancellation right, no repricing, no lapse. The scare version of this story is more memorable than the true one and it sells more policies. It is still not what the contracts say.

2. That international policies are portable. One insurer says so in writing, in a product guide rather than in policy conditions, and its own underwriting guide warns that an intention to move can mean no terms offered. We stay inside what is contractual, so the page describes what each wording does and declines the category claim.

3. What a supervisor says happens to a life policy when the holder emigrates. We looked. BaFin, the ACPR, FINMA, the Central Bank of Ireland and DNB/AFM publish nothing on it that we could find. BaFin does publish such a statement for German substitutive private health insurance — a different product under a different regime — and carrying it across to life would be exactly the kind of borrowed authority this page exists to avoid.

4. What any of this costs. No insurer in the set publishes rates we could quote as a primary source, so there are no premium figures anywhere on this page. A number we cannot show you the origin of is worth less than the space it occupies.

One correction while we are being exact, because it is the sort of thing that gets repeated between advisers: the Swiss reservation of heirs' reduction claims is not in the VVG. The current consolidated Insurance Contract Act, Stand 1 January 2024, contains no reference to the Pflichtteil at all. It lives in the ZGB, at Arts. 476 and 529. What the VVG does carry is the machinery around a nomination — the policyholder may nominate without the insurer's consent, the beneficiary holds an own right to the claim, and where the spouse, registered partner or descendants are beneficiaries the claim is shielded from the policyholder's creditors and survives a disclaimer of the estate.