Equitable Life, which manages life and pensions policies that are closed to new customers, has most of its 400,000 policyholders in Britain but also has a "few thousand" in Ireland and a similar number in Germany, Chief Executive Chris Wiscarson told Reuters.

"We are having to make sure we have plans in place to deal with whatever comes out of the next couple of years," he said, adding that the firm would "probably" set up a regulated subsidiary in Dublin and use so-called passporting rights to manage policies for customers in Germany, but no decision had been made yet.

Lloyd's of London and AIG are among a number of insurers to announce plans to set up EU subsidiaries, in the event that Britain loses access to the single market after Brexit.

Dublin, an early favourite for such bases, has lost out in several cases to centres such as Brussels and Luxembourg.

Equitable Life, which Wiscarson said has around 200 staff in total, would only employ a small number of staff in Dublin.

"In the great scheme of things, this is not a huge cost," he said.

The Bank of England has asked insurers and banks operating in Britain to outline their Brexit plans by mid-July.

(Editing by Robin Pomeroy)

By Carolyn Cohn