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The Insurance Commission, through Circular Letter No. 2018-74 dated 28 December 2018 (Circular Letter), issued the guidelines for admissibility of investments in infrastructure projects, thereby encouraging insurance and professional reinsurance companies to invest in infrastructure projects under the Philippine Development Plan (PDP) for 2017 to 2022.

Based on the Circular Letter, subject to certain conditions, insurance and professional reinsurance companies may invest either in debt and/or equity security instrument for the infrastructure projects under the PDP through the following participations:

  1. as project proponent in construction projects;
  2. as financiers or sponsors in project financing; or
  3. as regards operation and maintenance contract, through an existing public service facility which will require operation and maintenance and will be paid through consignment or service fees.

The Circular Letter provides that investments in infrastructure project with guaranty or with contingent liability fund will be considered as reserve investment. Further, investments in infrastructure project without guaranty or without contingent liability fund may likewise be considered as reserve investment subject to certain limitations.

Prior to approval of the investment, the Insurance Commission will require insurers to submit the financial statements of the infrastructure projects and assess the same to determine the risk impact on the insurer’s capital.

Actions to Consider

Insurance companies should take note of the (i) policy of the IC encouraging investments in infrastructure projects and (ii) the requirements for such investments to become admitted assets to address the insurer’s statutory net worth requirements under the Insurance Code.


Dennis Quintero is a partner in the Corporate & Commercial/M&A Practice Group of Quisumbing Torres. He heads the Firm's Energy, Mining & Infrastructure and Financial Institutions Industry Groups. He is part of the Firm’s Competition Focus Group. He is cited as a Market Leader by the IFLR 1000: Financial and Corporate Guide 2018-2020. He is consistently ranked as a leading individual in Corporate and M&A by The Legal 500 Asia Pacific and as a leading individual in Projects, Infrastructure, and Energy/Natural Resources and Mining by the leading international legal directories (i.e., Chambers Global and Asia Pacific, IFLR1000/The Petroleum Economist, and The Legal 500 Asia Pacific). Dennis is also a Certified Public Accountant. He was appointed co-chair of the 2013 Conference of the International Bar Association and Australian Resources and Energy Law Association Southeast Asia in Singapore. He is a member of the Association of International Petroleum Negotiators. He was cited as one of IFLR’s Asia’s Best Lawyers for 2019 and 2020 (Energy & Infrastructure, M&A, Project Finance) and among Asia Business Law Journal’s “A-List” of the Top 100 lawyers in the Philippines.


Kristina R. Navarro is an associate in Quisumbing Torres' Corporate & Commercial/M&A Practice Group and a member of the Financial Institutions Industry Group and Fintech Focus Group. She has five years of experience in financial services, fintech, and loans and credit facilities.