SecProbe.io

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                                               December 14, 2005

VIA EDGAR
Mr. Joseph Roesler
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

                  Re:  AXIS Capital Holdings Limited Form 10-K for year ended
                       December 31, 2004 filed on March 1, 2005
                       ------------------------------------------------------

         Set forth below is the revised response by AXIS Capital Holdings
Limited (the "Company") to the comments of the staff of the Securities and
Exchange Commission set forth in your letter dated October 27, 2005 relating
specifically to the Company's proposed 2005 critical accounting policy with
respect to reserves for losses and loss expenses.

Revised Disclosure

Reserve for losses and loss expenses. For most insurance and reinsurance
companies, the most significant judgment made by management is the estimation of
the reserve for losses and loss expenses, which we also refer to as loss
reserves. Our loss reserves are established based upon our estimate of the total
cost of claims that were reported to us but not yet paid or, case reserves, the
costs of additional case reserves on claims reported to us but not considered to
be adequately reserved, or ACR, and the anticipated cost of claims incurred but
not reported, or IBNR.

         For reported losses, we establish case reserves within the parameters
of the coverage provided in our insurance or reinsurance contracts. With respect
to our insurance operations, we are notified of insured losses by brokers and
insureds and record a case reserve for the estimated amount of the ultimate
expected liability arising from the claim. The estimate reflects the judgment of
our claims personnel based on general reserving practices, the experience and
knowledge of such personnel regarding the nature of the specific claim and,
where appropriate, advice of counsel. Reserves are also established to provide
for the estimated expense of settling claims, including legal and other fees and
the general expenses of administering the claims adjustment process.

         Our reinsurance business is predominantly short to medium tail in
nature, which typically allows us to determine the ultimate loss experience
within a relatively short period after a contract has expired. However, the
reserving process for our reinsurance operations is more complicated than for
our insurance operations. For reported losses, we generally establish case
reserves based on reports received primarily from brokers and also from ceding
companies. With respect to contracts written on an excess of loss basis, we
typically are notified of insured losses on specific contracts and record a case
reserve for the estimated amount of the ultimate expected liability arising from
the claim. With respect to contracts written on a pro rata basis, we typically
receive aggregated claims information and record a case reserve based on this
information.

         Following the occurrence of a reinsured loss, an insured notifies its
insurance company who then reports the information to its reinsurer, generally
via a broker. The period of time that elapses between the notification to the
insurance company and the reinsurance company varies depending upon a number of
factors such as: the type of business; whether the reinsurance is written on an
excess of loss or pro rata basis; the size of the loss; and whether the loss
information is provided by brokers or cedants. Typically, the delay can vary
from a few weeks to a several months. In addition, as reinsurers, we do not
separately evaluate each of the underlying risks assumed and, therefore, we rely
upon our cedants' underwriting, risk management and claims administration
practices. These factors necessarily create a higher degree of uncertainty in
establishing our estimate of loss reserves for our reinsurance operations than
for our insurance operations.

         In order to reflect this increased level of uncertainty in establishing
our loss reserves, some of our underwriting, claims and reserving practices have
been modified for our reinsurance business. In deciding whether to provide
treaty reinsurance, we carefully review and analyze the cedant's underwriting
and risk management practices to ensure appropriate underwriting, data capture
and reporting procedures. We also utilize an outsourced claims audit program
that allows us to review a cedant's claims administration to ensure that its
claim reserves are consistent with reinsured exposures, are adequately
established and are properly reported in a timely manner, and to verify that
claims are being handled appropriately. For those losses where we receive
contract-specific loss notifications, our claims department evaluates each
notification and may record ACRs if claims are not considered to be adequately
reserved. Where claims information is received in an aggregated form, our
reinsurance contracts typically require that pre-defined large losses must be
separately notified so that these losses can be adequately evaluated. As our
independent actuaries reserve on a line of business basis, their actuarial
methodology allows for reporting time lags when establishing ultimate loss and
loss expenses for reinsurance business. In addition, because we have limited
loss experience and insufficient claims development data to calculate credible
trends, our independent actuaries use industry data when establishing ultimate
loss and loss expenses for our reinsurance business.

         Loss reserving for catastrophe events in our insurance and reinsurance
businesses is an inherently uncertain process. When a catastrophe occurs, we
review our exposures to determine which exposures will be impacted by the event.
We contact brokers and clients to determine their estimate of involvement and
the extent to which their programs are affected. We may also use computer
modeling to estimate loss exposures under the actual event scenario. We
currently use Risklink version 4.5 licensed by RMS, Classic/2 and CATRADER
licensed by AIR and WORLDCAT Enterprise licensed by Eqecat. As part of the
underwriting process, we obtain exposure data from our clients, so that when an
event occurs we can run our models to produce an estimate of the losses incurred
by clients on programs that we insure or reinsure. Typically, we derive our
estimate for the losses from a catastrophic event by blending all of the sources
of loss information available to us. This estimate is derived by the claims team
and is known as "case IBNR". For catastrophic events, there generally is
considerable uncertainty underlying the assumptions and associated estimated
reserves for losses and loss expenses. Reserves are reviewed quarterly and as
experience develops and additional information is known, the reserves are
adjusted as necessary. Adjustments are reflected in the period in which they
become known.

         The estimate of our ultimate loss and loss expenses is determined every
quarter by Ernst & Young, who acts as our independent reserving actuary, and is
based on generally accepted actuarial principles. The independent actuaries
utilize various actuarial methodologies to arrive at a single point estimate for
baseline ultimate loss and loss expenses. The selection of an actuarial
methodology and the associated loss ratio is applied at a line of business level
to determine the ultimate loss and loss expenses by line of business. The
actuarial method is dependent upon characteristics specific to each line of
business, including the extent of company-specific loss experience, the maturity
of the line of business and the type of coverage. The actuarial methods utilized
include the Bornhuetter-Ferguson method, the initial expected loss ratio method
and the chain ladder ("loss emergence") method. The Bornhuetter-Ferguson method
takes as a starting point an assumed ultimate loss and loss expense ratio
developed by the actuaries and blends in the loss and loss expense ratio implied
by the experience to date. The chain ladder method uses the historical
development profile of incurred claims experience to project the more recent,
less developed profile of claims experience and to generate ultimate loss and
loss expenses. The initial expected loss ratio method estimates ultimate loss
and loss expenses based on pricing information. Due to our limited loss
experience, for most lines of business the independent actuaries utilize the
Bornhuetter-Ferguson method to derive a single point estimate of baseline
ultimate loss and loss expenses.

         For our insurance segment, the assumed ultimate loss and loss expense
ratios developed by the independent actuaries are based on benchmarks derived
from the independent actuaries' wider market experience together with our
limited historical data. These benchmarks are then adjusted for rating increases
and changes in terms and conditions that have been observed in the market and by
us. For our reinsurance segment, the assumed ultimate loss and loss expense
ratios are based on contract-by-contract initial expected loss ratios derived
during pricing together with benchmarks derived from the independent actuaries'
wider market experience. Under U.S. GAAP, we are not permitted to establish loss
reserves until an event that gives rise to a loss occurs. Consequently, on some
contracts that respond to highly visible, major loss events, we do not establish
general IBNR, and only hold case IBNR where a potential exposure has been
identified.

         Our independent actuaries apply loss and loss expense ratios to our
earned premium to generate estimated baseline ultimate costs of the losses. From
the estimated baseline ultimate costs of losses, we deduct paid losses and
reported case reserves to generate our baseline IBNR. The estimated baseline
ultimate costs of losses will almost certainly differ from our actual losses and
loss expenses. The uncertainty surrounding our actual losses and loss expenses
is greater for a company like ours that has a limited operating history and
claims loss development patterns. In addition, our limited operating history and
claims loss development patterns have necessitated the use of benchmarks in
deriving our IBNR. These benchmarks could differ materially from our actual
experience despite management's and the independent actuaries' care in selecting
them.

         To reduce some of the uncertainty, our independent actuaries perform,
in conjunction with management, an analysis of additional factors to be
considered when establishing our IBNR. These uncertainties are intended to
compensate for our limited operating history and claims loss development
patterns, which require the use of industry information that may not be
indicative of our actual loss experience. As at December 31, 2005 we recorded
additional IBNR for uncertainties relating to [the timing of the emergence of
claims.] We anticipate that these uncertainties may vary over time. A
combination of the baseline estimate of IBNR and the reserves for the additional
uncertainties produces a single point estimate that constitutes management's and
the actuaries' best estimate of IBNR.

<PAGE>

         The following table provides a breakdown of reserves for losses and
loss expenses by segment by type of exposure as of December 31, 2005, 2004 and
2003.

<TABLE>
<CAPTION>
                                                                       As of            As of          As of
                                                                    December 31,    December 31,    December 31,
                                                                        2005            2004            2003
                                                                   --------------  --------------  --------------
<S>                                                                <C>              <C>             <C>
Marine, aviation and aerospace...................................                   $      280.5    $      148.5
Onshore and offshore energy and property.........................                          421.6           251.5
Other specialty risks............................................                          179.8           $81.7
                                                                   --------------  --------------  --------------
Total--Global Insurance..........................................                   $      881.9    $      481.7
                                                                   ==============  ==============  ==============

Catastrophe (property and non-property)..........................                   $      394.3    $      165.6
Credit and bond..................................................                           18.5              --
Liability........................................................                           31.0              --
Other............................................................                           74.2            61.7
                                                                   --------------  --------------  --------------
Total--Global Reinsurance........................................                   $      518.0    $      227.3
                                                                   ==============  ==============  ==============

Professional lines and liability.................................                   $      460.5    $      174.4
Property.........................................................                          300.1           $49.4
                                                                   --------------  --------------  --------------
Total--U.S. Insurance............................................                   $      760.6    $      223.8
                                                                   ==============  ==============  ==============

Professional lines and liability.................................                   $      203.2    $       48.7
Property, marine and aviation....................................                           40.9            11.3
                                                                   --------------  --------------  --------------
Total--U.S. Reinsurance..........................................                   $      244.1    $       60.0
                                                                   ==============  ==============  ==============
Total reserves for losses and loss expenses......................                   $    2,404.6    $      992.8
                                                                   ==============  ==============  ==============
</TABLE>

         In estimating our ultimate loss and loss expenses, our independent
actuaries utilize actuarial methodologies that rely on the use of various
assumptions. As of December 31, 2005, the key assumptions used by our actuaries
were the establishment of initial expected loss ratios and the establishment of
development factors. Both of these assumptions are largely based upon industry
loss information, which may not be indicative of our actual loss experience. A
5% change in either of these assumptions would equate to $X million or     %,
of our total loss reserves, which change would represent % of net income and
    % of shareholders' equity. As of December 31, 2004, a 5% change in these
assumptions would equate to a $X million change in loss reserves, which change
would represent X% of net income and X% of shareholders' equity.

         The methodology of estimating loss reserves is reviewed each quarter to
evaluate whether the assumptions made continue to be appropriate. Any
adjustments that result from this review are recorded in the quarter in whic