Living abroad with sharia-compliant protection

Living abroad with sharia-compliant protection

Muslim expats: which takaful cover exists for health, life and repatriation, in the Gulf, in Malaysia or when leaving from France and Luxembourg.

Expatriates find takaful insurance mainly in countries with a dedicated framework, such as Malaysia or the Emirates, while in French-speaking Europe the offer is limited to a few life, funeral and repatriation contracts that must be examined clause by clause.

Three needs specific to life abroad

An employee posted or settled abroad must cover local medical care, protect the family in case of death and plan for possible repatriation of the body. Takaful meets these needs through separate family and general funds managed according to sharia.

Malaysia, a market open to all residents

Malaysian takaful is governed by the Islamic Financial Services Act 2013, under licence from Bank Negara Malaysia, and is open to people of any religion. Our guide to takaful in Malaysia details the players and rules of this market.

Expatriation in the Gulf and the DIFC

In 2009 the Zurich group launched Family Takaful through Zurich Takaful, a joint venture based in Dubai's DIFC. Expatriates settled in the Emirates can read our article on Islamic insurance in the UAE for the local offer.

What exists for someone leaving France

In France, Swiss Life launched the Salam takaful life contract in autumn 2013, and Luxembourg's Vitis Life offers Amane Exclusive Life with a minimum premium of 250,000 EUR. These savings contracts do not replace expatriate health insurance.

The Luxembourg case of unit-linked contracts

A Luxembourg life policy, supervised by the Commissariat aux Assurances, can be invested in Islamic ETFs. Strictly speaking this is not takaful, as there is no participants' fund or tabarru', but the tool appeals to some highly mobile expatriates.

Repatriating the body to the Maghreb or Africa

In March 2020 the broker SAAFI announced Sakina, a takaful death, funeral and repatriation offer from 2,000 to 7,000 EUR, reserved for French tax residents. Its current activity is unconfirmed; see also our page on repatriation of remains.

A public precedent for the Algerian diaspora

In January 2011 the Algerian state insurer SAA created a repatriation product for Algerians living in France, priced at 25 EUR per person per year and sold through BIA in Paris. This old rate shows that home-country solutions exist.

Expat health: where the takaful offer falls short

Our research found no international takaful health insurance aimed at expatriates leaving France. You must therefore compare conventional international plans, or take local cover from a takaful operator in the host country where the law allows it.

Why Europe remains difficult ground

At the IFM summit in London in November 2014, Solvency II was described as the biggest challenge facing takaful. In the United Kingdom, Salaam Halal Insurance, launched in 2008 after raising 60 million pounds, went into run-off within a year.

Checking the model of a policy bought locally

In the host country, ask whether the operator uses wakala, mudaraba or the hybrid wakala-waqf model from Pakistan. Surplus sharing depends on it: everything goes to participants under wakala, while under mudaraba it is divided with shareholders.

Returning home and continuity of cover

A local takaful policy often ends with the residence permit. Before going home, check the date cover stops, what happens to sums built up in a participants' investment fund and whether savings can be surrendered or transferred.

Takaful windows and dedicated operators

In Pakistan, the SECP's Takaful Rules 2012 allow conventional insurers to open takaful windows, following Indonesia's example. An expatriate should therefore distinguish a window, backed by a conventional insurer, from a fully dedicated takaful company.

Building compliant expatriate cover

  1. List your needs: local medical care, family protection, repatriation and savings, according to the planned length of your stay abroad.
  2. Identify the takaful operators licensed in the host country, such as by Bank Negara Malaysia in Malaysia.
  3. Ask for the management model and the sharia board's fatwa for every contract offered.
  4. Compare contributions, wakala fees, any mudaraba share and the rule for redistributing the surplus.
  5. Check the geographic area covered, the exclusions and the automatic end of the contract when you leave the country.
  6. Keep repatriation cover that does not depend on your country of residence, to avoid any gap when you move.

Cost components of expatriate takaful protection

ElementContract concernedBenchmark or factor
Tabarru' contributionHealth, death, disabilityAge, country of residence, scope of care
Wakala feeAll takaful contractsRate specific to each operator
Minimum savings premiumHigh-end life policy in Luxembourg250,000 EUR for Amane Exclusive Life (2014)
Repatriation benefitFuneral and repatriation2,000 to 7,000 EUR for Sakina (2020, indicative)
Surplus redistributedParticipants' risk fundClaims experience, wakala or mudaraba model

Documents expatriates are asked for

Frequent missteps by expatriates

Expatriates' questions about takaful

Can a non-Muslim take out takaful abroad?

Yes in Malaysia, where takaful governed by IFSA 2013 is open to everyone regardless of religion. Elsewhere, conditions depend on each operator, but our sources do not generally report religious affiliation as a membership criterion.

Does international takaful health insurance exist?

Our research identified none aimed at expatriates leaving France. The realistic options are local takaful cover in a country with operators, or a conventional international plan whose clauses and investments you examine carefully.

Does my French takaful life contract follow me abroad?

A savings contract such as Swiss Life's Salam normally remains active, but taxation and the ability to make payments depend on your country of residence. Ask the insurer before leaving, as a change of tax residence can alter the contract.

How can I fund repatriation to Morocco or Algeria?

Through a funeral plan with a repatriation option, a dedicated takaful offer if available, or a product from an insurer in the home country, as Algeria's SAA did in 2011. Check limits, the companion's ticket and the waiting period.

Which authority supervises takaful bought in Malaysia?

Bank Negara Malaysia issues licences and supervises operators. Its draft framework of May 2018 requires surpluses and deficits to be kept separate by fund and participants' consent for any revision of the tabarru'.

Verified sources and bodies

Atlas Magazine: first takaful policies in France2014 article presenting Swiss Life's Salam and Vitis Life's Amane Exclusive Life, the first takaful life contracts offered to French residents.Bipiz: Zurich Family Takaful at the DIFCOverview of the 2009 launch of Zurich's Family Takaful by a joint venture based in the Dubai International Financial Centre.Actuarial Partners: BNM takaful frameworkAnalysis of the draft takaful operating framework published by Bank Negara Malaysia in May 2018, useful for expatriates living in Malaysia.Algerie360: SAA repatriation2011 article on the body repatriation product launched by the Algerian state insurer SAA for Algerians living in France.

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