Country Comparison Tables

This document provides side-by-side comparison tables across seven regulatory dimensions for all 18 jurisdictions studied in this research project. Each table synthesises data from the individual country regulation files in

Americas,

Europe,

Asia-Pacific, and

Middle East & Africa regions, as well as from the guidance documents on licensing, coverage gaps, deposit guarantees, market capacity, claims history, DeFi insurance, and captive structures.

The 18 jurisdictions are: United States, Bermuda, Canada, Cayman Islands (Americas); Australia, Hong Kong, Japan, Singapore, South Korea (Asia-Pacific); European Union, France, Germany, Liechtenstein, Switzerland, United Kingdom (Europe); Bahrain, United Arab Emirates, and the Emerging Markets group (Brazil, Nigeria, South Africa, India) (Middle East & Africa). Of these 18, 6 impose mandatory or mandatory-in-substance insurance (Hong Kong, South Korea, United Arab Emirates, Bahrain, Canada, Cayman Islands), while the remaining 12 are voluntary, insurance-or-capital, emerging, or no-framework regimes. No deposit or investor guarantee scheme covers unbacked crypto-assets in any of the 18 — the sole partial exception is Liechtenstein, where DLT security tokens (not unbacked crypto) are eligible for investor compensation up to CHF 30,000. The United Kingdom is added as the global Lloyd's hub jurisdiction (Europe region) even though it imposes no mandate.

Cells marked "No data" indicate that no verified information was found in the source files. Cells marked "N/A" indicate the dimension does not apply to that jurisdiction. Market-capacity, premium, and per-policy figures are self-reported by the named provider/aggregator unless otherwise sourced, and are flagged as such.

Table 1: Insurance Mandate Status

This table captures whether each of the 18 jurisdictions mandates digital asset insurance, the legal basis, coverage type, minimum amounts, and effective dates. Mandatory-in-substance means insurance is a gating factor or prescribed category (often on an "insure-or-mitigate" basis) rather than a hard numeric mandate.

Table 2: Insurance Provider Landscape

This table compares domestic insurance capacity, Lloyd's access, specialty MGAs/coverholders, and broker presence across the 18 jurisdictions. Per-policy and facility figures are self-reported unless sourced.

Table 3: Deposit / Investor Guarantee Coverage

This table compares whether traditional deposit or investor guarantee schemes cover digital assets, scheme limits, and the alternative protection mechanism. No scheme covers unbacked crypto in any of the 18 jurisdictions; Liechtenstein's EAS is the only partial exception (DLT security tokens only).

Table 4: Insurance Licensing Requirements

This table compares insurance licensing pathways relevant to digital asset insurance providers across the jurisdictions where the matrix records a pathway.

Table 5: Claims History & Recovery

This table documents major incidents recorded in the matrix, the jurisdiction involved, loss amounts, insurance recovery (if any), and the recovery mechanism used. Figures are as reported in the per-jurisdiction files.

DeFi/parametric, EU, France, Germany, Liechtenstein, Switzerland, UK, Bahrain, UAE, and Emerging-Market files record no jurisdiction-specific insured-loss claim or recovery event (NO DATA / NOT VERIFIED). Lloyd's claims-level data is confidential and not disclosed. Global recovery rates remain low — only ~4.2% of stolen assets recovered globally in H1 2025 (EU file).

Table 6: DeFi / Parametric Insurance Classification

This table compares how the jurisdictions that the matrix addresses classify DeFi insurance protocols and parametric/on-chain insurance. DeFi-insurance protocol figures (Nexus Mutual capital pool, claims paid, active cover) are self-reported by the protocol.

Table 7: Regulatory Direction

This table assesses whether each jurisdiction's digital asset insurance regulation is tightening, balanced/stable, or permissive, with evidence and upcoming changes from the matrix.

International Standards Context

Across the 18 jurisdictions, supranational insurance and AML standards remain unsettled. The FATF's sixth Targeted Update (26 June 2025) reported that, of 138 jurisdictions assessed for Recommendation 15 (new technologies and VASPs), only ~1% were fully compliant and 29% (40 of 138) largely compliant, while 49% were partially compliant and 21% non-compliant — i.e. roughly 70% are not yet largely or fully compliant. See FSB / BIS / FATF standards, IAIS, and IOSCO for the international-frameworks layer.

Abbreviations

Verification Notes

• Source of truth: This refresh mirrors .claude/digital-asset-insurance-fact-matrix.json (canonical per-jurisdiction facts, tables t1-t7) as of 2026-06-04. No web search was performed; no fact was introduced that is not in the matrix or the prior version of this file. Aggregates ("X of N") are computed for N = 18 jurisdictions.
• 18 jurisdictions: United States, Bermuda, Canada, Cayman Islands, Australia, Hong Kong, Japan, Singapore, South Korea, European Union, France, Germany, Liechtenstein, Switzerland, United Kingdom, Bahrain, United Arab Emirates, and the Emerging Markets group (Brazil, Nigeria, South Africa, India). Mandatory or mandatory-in-substance: 6 (Hong Kong, South Korea, UAE, Bahrain, Canada, Cayman Islands).
• Mandatory vs voluntary distinction: Canada and Cayman are "mandatory in substance" (insurance is a gating factor / prescribed insure-or-mitigate category, no numeric minimum), distinct from Hong Kong/South Korea/UAE/Bahrain hard mandates and from the EU/France/Germany/Liechtenstein insurance-or-capital option (voluntary). Japan has no current mandate (PSA) but a proposed FIEA liability reserve. Australia is voluntary PI-only under an enacted-but-not-yet-in-force framework (commences 9 Apr 2027).
• Deposit-scheme inclusion vs exclusion: All 18 schemes exclude unbacked crypto. Liechtenstein's EAS is the sole partial exception (DLT security tokens eligible up to CHF 30,000; BTC/ETH excluded). US FDIC GENIUS-Act NPR (7 Apr 2026) bars pass-through insurance for stablecoin reserves. Canada CIPF covers cash and crypto ETFs/fund units, not direct crypto. The UAE entry in Table 3 is the VARA ETD Insurance Fund (a default-protection buffer), not a depositor scheme.
• Regulated insurance vs discretionary mutual: Nexus Mutual is a UK discretionary mutual (company limited by guarantee, co. no. 10917763) — not regulated as insurance under FSMA and not MAS-/EU-licensed; cited via the protocol/company record, not via Medium. Munich Re's Smart Contract Risk Insurance (Germany) is, by contrast, a regulated commercial product. Bermuda's proposed PSPI and Cayman's SPC/transformer vehicles are regulated structures.
• Self-reported figures: Market-capacity, premium, per-policy, and coverage figures (e.g. Marsh USD 825M facility, Evertas/Arch up to US$420M per policy, Singapore SRA cyber pool up to US$1B, OSL US$1B HK programme, Germany ~53 CASPs, ABIR Bermuda GWP, Cayman 720 captives / USD 51B premiums) are self-reported by the named provider/aggregator/regulator and flagged accordingly; not independently re-verified this cycle.
• Key corrections this cycle: US (FDIC GENIUS-Act NPR Apr 2026, no pass-through for stablecoin reserves; SEC/CFTC joint interpretation 17 Mar 2026); Canada (Stablecoin Act Royal Assent 26 Mar 2026, not in force; CIRO 20% self-custody allowance; mandatory-in-substance gating); Cayman (first full VASP licence to BCXPro 5 Feb 2026; MC-RSOG insure-or-mitigate effective Feb 2026 — upgraded from disclosure-only); Australia (Framework Act Royal Assent 8 Apr 2026, commences 9 Apr 2027; AML/CTF existing entities 31 Mar 2026, tranche-2 NEW sectors 1 Jul 2026); Hong Kong (13 VATPs; IA RBC 100% downward stress, conclusions 8 May 2026; HKDPB limit HKD 500,000); Japan (FIEA Cabinet-approved 10 Apr 2026, penalty 10 yr / JPY 10M; reserve sized to volume/incident, not a JPY 2-40B figure); Singapore (37 MPIs with DPT activity; Evertas/Arch up to US$420M per policy, self-reported); South Korea (no-fault liability PROPOSED, not enacted; DABA phase-2 bill 8 Apr 2026); EU (Solvency II Delegated Reg (EU) 2026/269, OJ 18 Feb 2026 — NO crypto charge; EIOPA 100% stress still pending a subsequent delegated act; MiCA transition ends 1 Jul 2026); France (DASP transition ends 1 Jul 2026); Germany (~53 CASPs, largest EU market, self-reported); Liechtenstein (MiCAR authorisation by 1 Jul 2026; EAS is a PCC); Bahrain (separate Digital Tokens 2023 + Stablecoin SIO frameworks); FATF (R.15: of 138 jurisdictions assessed 2025, ~1% fully / 29% largely compliant).
• Tags / regions: Tagged with the canonical type/analysis. The five canonical regions used are Americas, Asia-Pacific, Europe, and Middle East & Africa (with International Standards as the cross-cutting frameworks layer); the matrix's lowercase region values (asia-pacific, middle-east-africa) map to these canonical names.
• Wikilinks: Same-domain links use the deep-research/digital-asset-insurance/ path prefix (basenames such as canada/japan/united-states/european-union are ambiguous across deep-research domains); cross-domain links would use the deep-research/ prefix. File slugs match the regulation/guidance filenames (e.g. united-states, european-union, cayman-islands, fsb-bis-fatf). </content>

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