New investment rules for Luxembourg unit-linked life insurance products – CAA Circular Letters 26/1 and 26/2

This training is designed for professionals involved in the design, distribution, investment management, administration and oversight of Luxembourg unit-linked life insurance products, including:

• Internal audit and control functions
• Asset managers and custodian/depositary banks
• Private banks and wealth managers
• Life insurance undertakings

This training is particularly relevant for professionals working with Luxembourg life insurance products distributed internationally.

It is critical to understand the new regulatory framework and its practical implications for insurance undertakings and their business partners.

Upon completion of the training, participants will be able to:

• Identify key operational and compliance challenges and the governance, documentation and control measures relevant to implementing the new requirements.
• Understand the respective roles and responsibilities of insurance undertakings, distributors, asset managers and depositary banks.
• Assess the implications for product governance and policyholder protection, including target market identification, transparency and value-for-money requirements.
• Identify the investment rules and restrictions applicable to different policyholder categories and investment structures.
• Understand the new regulatory framework governing Luxembourg unit-linked life insurance products and identify the principal changes introduced by CAA Circular Letters 26/1 and 26/2.

This training provides an overview of the regulatory changes introduced by CAA Circular Letter 26/1, effective from 1 February 2026, together with the amendments introduced by CAA Circular Letter 26/2 to the depositary framework.

• Regulatory framework and key developments
• Policyholder classification and investment rules
• Product governance and policyholder protection
• Operational implications and implementation
• Practical illustrations: Interactive case studies, examples of investment eligibility and discussions of implementation challenges.

This training is coordinated by Anthony Dault, Partner and Antonella Argalia, Senior Manager at PwC Luxembourg.

• Anthony is a partner specialised in insurance/reinsurance and international tax structure, and is actively involved in PwC Luxembourg Reinsurance and Insurance Group (RIG), including the insurance and reinsurance regulatory team. Anthony has more than 20 years of experience serving several multinationals, subsidiaries of European and US registered companies reporting under IFRS or Lux GAAP in the insurance and reinsurance sector. In the past years, Anthony has been involved in the development of the PwC Luxembourg insurance regulatory practice, with a strong focus on cross-border distribution as well as regulatory licensing projects. In that context, he co-heads the IDD service offering of PwC Luxembourg, and is a member of the ACA IDD working group.
• Antonella is a senior manager in PwC Luxembourg’s insurance practice, with over 25 years of experience in the European insurance industry. She held product management roles at several leading life insurance companies in Luxembourg. She specializes in regulatory projects, product development, and marketing, focusing on wealth solutions for (U)HNWI using unit-linked life insurance products. She is a key contact for insurance regulations, distribution, and product suitability, and leads IDD assistance projects for insurance companies and intermediaries. Her expertise also includes insurance due diligence and regulatory analysis, making her a trusted advisor in the sector.