Introduction
Namibia’s Financial Institutions and Markets Act (FIMA), together with the regulations and standards made under it, came into operation on 1 May 2026. Namibian insurers are now regulated under a new prudential framework: Namibia Financial Institutions Supervisory Authority (NAMFISA) insurance standards covering capital adequacy, cell captives, commission and governance, dedicated microinsurance regulations and NSAP 104 as the actuarial standard for the valuation of long-term insurers.
South African insurers have been under the Solvency Assessment and Management (SAM) regime since 1 July 2018. With the Namibia dollar pegged to the rand at par, and many insurers operating on both sides of the border, the two regimes invite comparison. The headline numbers look similar. The bases behind them are not.
Key features of the new Namibian regime
- Minimum capital floors: NAD 8 million for an insurer writing more than one class, NAD 2 million for a single class, NAD 200,000 for a funeral-only or microinsurance-only insurer, and NAD 12 million for a reinsurer. The floor is measured on paid-up capital and retained earnings only.1
- Life insurance: NSAP 104 2 prescribes a financial soundness valuation with compulsory margins on all best estimate assumptions, plus discretionary margins at the valuator’s choice. The Solvency Capital Requirement (SCR) is the greater of a termination capital requirement and an ordinary capital requirement, calibrated to approximately 95% confidence of meeting all liabilities on a run-off basis. This is substantially the pre-SAM South African statutory basis, written for Namibia around the same time South Africa retired it.
- Non-life insurance: a factor formula. The SCR is a basic solvency capital requirement (insurance, market and credit risk charges combined) plus an operational risk amount, calibrated to a 95% confidence level over one year, a one-in-20 event. Insurance risk factors are fixed percentages of net written premium by class, from 20% (vehicles) to 50% (guarantee and aviation).1
- Cell captives: NAD 200,000 minimum capital per cell, and a diversification credit of up to 15% when aggregating cell SCRs,1 registered insurance brokers and their affiliates may not hold cell shares.
- Microinsurance: benefits capped by a schedule (NAD 25,000 on most lines, CPI linked)3, a 30-day file-and-use product route, and widened distribution including funeral parlours, co-operatives and microfinance institutions.
- Internal models: permitted for life insurers with NAMFISA approval. 2
Namibia and South Africa at a glance
Figure 1: Comparing Namibian and South African insurance regimes
| Namibia | South Africa4 | |
|---|---|---|
| Regulator | NAMFISA | Prudential Authority |
| Framework | FIMA (Act 2 of 2021), NAMFISA insurance standards, NSAP 104 | Insurance Act 2017, Financial Soundness Standards (FSI/FSM), SAM |
| In force | 1 May 2026 | 1 July 2018 |
| Life valuation | Financial soundness valuation: best estimate plus compulsory margins | Market-consistent best estimate plus risk margin |
| Capital calibration | Approximately 95%, run-off adequacy | 99.5% value-at-risk over one year |
| Non-life capital | Factor formula on premiums and reserves, 95% over one year | Stress- and volatility-based standard formula |
| Minimum capital | NAD 8m (multiclass), NAD 2m (one-class), NAD 200,000 (funeral- or micro-only), NAD 12m (reinsurer) | ZAR 15m (insurer), ZAR 30m (composite reinsurer), ZAR 4m (microinsurer) |
| Cell capital | NAD 200,000 per cell; up to 15% diversification credit | Notional SCR per cell, minimum ZAR 1m (ZAR 250,000 for a microinsurance cell); no diversification with the promoter |
| Internal models | Variation of the SCR permitted, subject to NAMFISA approval. NSAP 104 permits internal models for long-term insurers, subject to NAMFISA approval. | Permitted, Prudential Authority approval |
Sources: Government gazettes 8901 and 8907; NSAP 104; Prudential Authority FSI 3, 4 and FSM.
What this means for insurers
The two regimes answer different questions. A Namibian non-life requirement is a one-in-20 number over one year; the South African requirement beside it is a one-in-200 number. The Namibian life basis is a run-off adequacy test carried by prudent margins; the South African one is a one-year stressed loss of own funds (broadly the same as excess assets over liabilities). With the currencies at par, it is tempting to read the figures across. They are not the same measurement.
For groups operating in both countries, the Namibian entity’s capital cannot simply be folded into a SAM group view. Translating between the bases, and explaining the bridge to boards and regulators, is now a recurring piece of work.
For new entrants, Namibia’s gates are set deliberately low for microinsurance and cells, at NAD 200,0001, against ZAR 4 million5 for a South African microinsurance license. The lighter entry comes with the full governance standards and, for life business, the full NSAP 104 valuation.
And for anyone who worked in South African life insurance before 2018, the Namibian basis will be familiar. The compulsory margins, the termination and ordinary capital requirements, and the run-off calibration all carry forward the pre-SAM statutory basis.
How Milliman can help
Milliman has supported insurers, and their boards, through licensing, capital modelling, statutory valuations and regime transitions in both markets, including the South African transition to SAM and its earlier statutory basis, which Namibia’s new framework substantially carries forward. We would be glad to discuss what FIMA means for your business.
1 NAMFISA Standard INS.S.2.1. The full text of the FIMA and standards commencement from 8 May 2026 is available from Government Gazette 8907, retrieved on August 7, 2026 from https://archive.gazettes.africa/archive/na/2026/na-government-gazette-dated-2026-04-30-no-8907.pdf.
2 Namibian Standard of Actuarial Practice (NSAP) 104, June 2018. For more information on life valuation, see the full text. Retrieved on August 7, 2026 from https://www.san.org.na/media/san/downloads/nsap_104_jun_18_docx.pdf.
3 Government Gazette of the Republic of Namibia. No. 8901. 30 April 3036. Annexture 1. Retrieved on August 7, 2026, from Government Gazette 8901.
4 For more information on South Africa’s Prudential Standards, read FSI 3, FSI 4 and the FSM series.
5 South Africa Reserve Bank. Prudential Standard FSM 1: Framework for Financial Soundness of Microinsurers. Retrieved on August 7, 2026 from https://www.lawexplorer.co.za/StatutoryDatabase/SubordinateFile/SubordinateFileDownload/8007. For more information about microinsurance in Namibia, read Namibia’s Government Notice 149 and Government Gazette 8901.