Company-Owned Life Insurance (COLI)

What Is Company-Owned Life Insurance (COLI)?

Company-owned life insurance (COLI) is a life insurance policy that pays a benefit to the company if an insured employee dies.

Key Takeaways

  • Company-owned life insurance (COLI) is a life insurance policy that pays a benefit to the company if an insured employee dies.
  • Company-owned life insurance policies can help cover the expenses associated with replacing an insured employee upon that person’s death.
  • Because companies used COLI policies to exploit tax loopholes, the Internal Revenue Service now requires that they meet certain conditions to receive a tax-free death benefit.

Understanding Company-Owned Life Insurance (COLI)

Company-owned life insurance (COLI), also referred to as corporate-owned life insurance, is a policy taken out on one or more critical employees. The company pays the insurance premiums and receives the death benefit if a covered employee dies.

COLI policies are a way for a company to minimize its tax burden, increase after-tax net income, finance employee benefits, and help cover the expenses associated with replacing an insured employee upon that employee’s death. COLI policies typically continue to cover employees up to the year after they leave the company.

COLI Requirements

Because some companies used COLI policies to exploit tax loopholes, the Internal Revenue Service (IRS) now requires that they meet certain conditions to receive a tax-free death benefit. For example, the company can only purchase COLI policies for the top 35% of employees, ranked according to their compensation. In addition, it must notify the employee in writing of the terms of the policy and obtain their written consent before purchasing.

History of COLI

COLI first appeared as a way for companies to insure against the death of a key employee, such as a top-level executive. However, tax loopholes made COLI very appealing to many companies. Companies attempting to exploit those loopholes began purchasing policies on lower-ranking employees without telling them and continued to pay premiums even after they left the company.

The practice reached its peak in the 1980s when decreasing regulation prompted some companies to insure a majority of their employees, borrow against the cash value of the policies, and deduct the interest on the loans.

In the late 1980s and 1990s, Congress responded by passing laws that require employee consent and an "insurable interest" on the part of the company. This meant that companies had to show the potential for loss due to an employee’s death to justify the purchase of a COLI policy. At the same time, the IRS reduced the ability of a company to deduct interest payments when borrowing against the policies.

Companies would often claim that they spent the payouts on employee benefits; however, there was no requirement to do so. The companies didn’t even need to disclose how they spent the money.

In the first decade of the 2000s, large corporations paid millions of dollars to settle lawsuits from family members of deceased employees who argued that the practice was unlawful. Later, Congress passed the COLI Best Practices Provision, as part of the Pension Protection Act of 2006, which introduced conditions for tax-free benefits. Consequently, while COLI policies still offer financial advantages to employers, they are subject to greater regulation.

What Is a Stock-Owned Insurance Company?

A stock company is owned by outside shareholders, while a mutual company is an insurance company that is owned by policyholders. For example, one of the largest mutual life insurance companies is Northwestern Mutual, while Prudential is one of the largest stock insurance companies. 

Are Company-Owned Life Insurance Premiums Deductible?

Premiums paid for a company-owned life insurance policy are counted as expenses and tax-deductible for the business—assuming the coverage is for executives or employees of the company.

Can Company-Owned Life Insurance Proceeds Be Taxed?


Proceeds from company-owned life insurance policies are not taxable for the company if two conditions are met—notice must be given to the covered employee and that employee must give written consent for coverage before it’s written. As well, businesses must report company-owned life insurance policies to the Internal Revenue Service (IRS) yearly via Form 8925.

Article Sources
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  1. Congressional Research Service. "Corporate-Owned Life Insurance (COLI): Insurance and Tax Issues," Pages 1-2.

  2. Congressional Research Service. "Corporate-Owned Life Insurance (COLI): Insurance and Tax Issues," Page 3.

  3. Internal Revenue Service. "Notice 2009-48," Pages 6-7.

  4. Congressional Research Service. "Corporate-Owned Life Insurance (COLI): Insurance and Tax Issues," Pages 3-4.

  5. Fidelity Life. “Is life insurance tax deductible?

  6. Internal Revenue Service. “Treatment of Certain Employer-Owned Life Insurance Contracts.”

  7. Internal Revenue Service. “About Form 8925, Report of Employer-Owned Life Insurance Contracts.”