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The Captive Record

A model compliance calendar for the Vermont pure captive — every deadline, cited

The recurring obligations of a Vermont pure captive on a calendar year, assembled from the statute itself. The citation sits beside every date, because a deadline without a citation is a rumor.

The Captive Record · June 9, 2026 · Filed under Standards · Verified against 8 V.S.A. ch. 141 as amended through the 2025 session

Vermont licenses more captives than any other U.S. domicile, and its filing calendar is the de facto template the industry carries in its head. This piece writes the template down — for the common case of a pure captive insurance company on a calendar fiscal year — with the primary authority for every date. Other entity types (sponsored, RRG, SPFC) share the skeleton but diverge in important places; those calendars get their own treatment.

Annual cycle — Vermont pure captive, calendar year end
ObligationDueAuthority
Annual report of financial condition ("VCAR"), verified by two executive officersPrior to Mar 158 V.S.A. § 6007(b)
Premium tax return and payment — filed electronically through myVTax (Form CPT-635); no estimated paymentsMar 158 V.S.A. § 6014; Vt. Dep't of Taxes
License renewal; license year ends April 1 ($500 renewal fee)Apr 18 V.S.A. ch. 141
Audited financial statementsJun 30DFR Reg. C-81-2
Statement of actuarial opinion on loss reservesJun 30DFR Reg. C-81-2
Board of directors meeting held in Vermont (at least one annually); resident director requirementWithin year8 V.S.A. § 6006(g)
Financial examination by the Commissioner≥ every 5 yrs8 V.S.A. § 6008

The fiscal-year election and its knock-on effect

A pure captive may apply to report on a fiscal year end rather than the calendar year. Granting the election does not simply move one date — it splits the reporting obligation. Under § 6007(c), the annual report becomes due 75 days after fiscal year end, but the captive must still file the premium schedule of the annual report prior to March 15 for each calendar year, because the premium tax base stays on the calendar year. Audited financials follow the fiscal year: due within 180 days of FYE. Captives that calendar the election's new date and forget the residual March filing discover the gap in a deficiency letter.

Worth knowing: the Vermont Department of Taxes observes weekend rolls on the premium tax deadline — its published schedule shows the return for the period ending 12/31/2025 due March 16, 2026, March 15 being a Sunday. The statutory date and the administered date are different facts; track both.

What this calendar deliberately omits

Event-driven obligations don't live on a calendar but bind just as hard: prior approval for material changes to the plan of operation, dividend approvals, and the like. And this is the pure captive calendar — a Vermont RRG layers on the NAIC annual statement (March 1, with a possible 30-day extension under 8 V.S.A. § 3569), quarterly NAIC filings, risk-based capital, ORSA, and the chapter 142 governance package; sponsored captives, SPFCs, and affiliated reinsurance companies each diverge from the skeleton in their own ways. Entity type is the first question, not a footnote.

One more caution, which is really the thesis of this publication: sister-state captive statutes are drafted from common ancestors and read nearly identically — with different numbers in them. Missouri's annual report is due prior to March 1, not March 15; its premium tax return is due February 1 with payment May 1. A Vermont habit applied in another domicile is a missed filing waiting to happen. Verify in the domicile's own text, every time.

Authorities: 8 V.S.A. §§ 6006, 6007, 6008, 6014 (current through the 2025 legislative session, including 2025 Act 23); DFR Regulation C-81-2; Vermont Department of Taxes, Captive Insurance Premium Tax (Form CPT-635). Missouri comparison: Mo. Rev. Stat. §§ 379.1312, 379.1326.

Educational and standards commentary only — not legal, tax, or investment advice, and no professional relationship is created. Dates verified against the cited primary sources as of June 9, 2026; statutes and regulations change, and elections, waivers, and entity-type differences alter every calendar. Confirm with the domicile regulator and your advisors before relying on any date.