Selling variable products needs a securities license too
The insurance license alone is not enough. Variable life and variable annuities are securities as well as insurance contracts, and the Texas Insurance Code itself defines them by their federal prospectus obligation. You need the insurance license and a separate securities registration, and the exam tests only the first.
Variable universal life is on the content outline. Variable annuities are on the content outline. You will study them, be examined on them, pass, get licensed, and then discover you cannot sell either one yet.
This is the most common late surprise in Texas life licensing and it is nobody's fault in particular. The insurance exam covers insurance law. Securities law is federal and lives somewhere else entirely.
The Insurance Code says it out loud
You do not have to take our word for the dual character of these products, because Texas wrote it into the statute. Chapter 1114, which governs replacement of life insurance policies and annuity contracts, defines a "registered contract" as a variable annuity contract or variable life insurance policy subject to the prospectus delivery requirements of the Securities Act of 1933.
That is the Texas Insurance Code pointing at a federal securities statute to describe a product it also regulates as insurance. Two regimes, one contract. The chapter then gives registered contracts their own treatment in the replacement rules: they are exempt from providing illustrations or policy summaries and must identify the appropriate prospectus or offering circular instead.
Texas lets the prospectus stand in place of the insurance disclosure documents. A regulator only does that when it accepts that another regulator is already covering the ground. If a prospectus is the disclosure, somebody registered has to deliver it.
What the insurance license does cover
The General Lines life, accident and health license is the correct insurance license for these products. Chapter 4054 says a person acting as an agent who writes fixed or variable annuity contracts or variable life contracts is required to hold this license, and the narrower Life Agent license carries the same line. So the insurance side is settled by passing this exam and applying.
| Product | Texas insurance license | Securities registration |
|---|---|---|
| Whole life, term life, universal life | Required | Not required |
| Fixed annuity | Required | Not required |
| Indexed annuity | Required | Depends on the product's structure |
| Variable life and variable universal life | Required | Required |
| Variable annuity | Required | Required |
| Accident, health and HMO coverage | Required | Not required |
The indexed row is the honest one. Indexed products sit on a spectrum and how a particular contract is structured decides whether it is a registered security. We are not going to give you a rule for that, because the answer belongs to the specific product and to the carrier's compliance department, not to a licensing exam.
The bit we are not going to make up
We hold 47 chapters of the Texas Insurance Code, the content outlines, the candidate handbook and TDI's examination report. We hold nothing about FINRA registration, which is the body that actually administers the securities examinations, and the securities side is federal rather than a Texas licensing matter at all.
So we are not going to tell you which securities examination you need, what it costs, how long it takes, or in what order to sit them. Those are real questions with real answers and we have not sourced them. What we can tell you with a citation is that the Texas Insurance Code treats variable contracts as prospectus-delivery products, which is the fact that makes the question necessary in the first place.
Ask the carrier that is recruiting you. They sponsor these registrations, they know their own product shelf, and they will have a sequence they want you to follow.
How this changes your exam preparation
It does not. That is the point worth making.
Variable products are examinable on InsTX-LAH05 whether or not you will ever sell one. The outline lists variable whole life and variable universal life under interest and market-sensitive products, and fixed and variable annuities under annuities. Skipping them because you plan to sell term insurance is how a candidate hands back questions they could have had.
Our opinion: study variable products as insurance contracts with an investment component, not as investments with an insurance wrapper. The exam is written by insurance people and tests the insurance treatment. The separation of account assets, the death benefit guarantee, who bears the investment risk. That framing gets you the marks.
Where this page stops
The concession is that this page cannot finish the job. It tells you the second license exists and it will not tell you how to get it, which is unsatisfying and better than guessing.
Common questions
Can I sell variable annuities with just a Texas insurance license?
No. Variable annuities and variable life are securities as well as insurance contracts, and a securities registration is needed alongside the insurance license. The Texas Insurance Code defines them by their obligation to deliver a prospectus under the Securities Act of 1933.
Which Texas insurance license covers variable products?
The General Lines life, accident and health license. Chapter 4054 of the Insurance Code says a person writing fixed or variable annuity contracts or variable life contracts must hold this license, and the narrower Life Agent license carries the same provision.
Are variable products on the Texas exam?
Yes. The content outline effective 1 September 2026 lists variable whole life and variable universal life under interest and market-sensitive products, and fixed and variable annuities under annuities. They are examinable whether or not you end up selling them.
Do indexed annuities need a securities license?
It depends on how the particular contract is structured, and we are not going to publish a rule that covers all of them. That question belongs to the specific product and the carrier's compliance department rather than to a licensing examination.
Which securities exam do I need?
We do not publish an answer to that. The securities side is federal and administered by a body whose materials we do not hold, so naming an examination would be a guess. Ask the carrier sponsoring you, since they register their own agents.