The Federal Government is considering introducing a "premium test" into the exemptions to the DOFI bill, but the exact limit remains under discussion.

A premium test is "still under consideration," Treasury's Manager of the Insurance Access and Pricing Unit, Vicki Wilkinson, said on Friday.

Speaking at an ICA seminar in Sydney, she said a number of submissions to the Australian Prudential Regulation Authority (APRA) discussion paper supported including a premium test in the high-valued insured exemption - the first of three so-called "limbs".

NIBA has been lobbying Treasury for a lower limit on the premium test, CEO Noel Pettersen told insuranceNEWS.com.au.

"Treasury appeared to accept the benefits of including a premium element in the high value insured exemption but indicated a desire for a higher figure than the $50,000 put forward by NIBA," he said.

"NIBA responded by indicating that raising the figure would increase the complexity and cost of administration as more exemptions would have to be considered individually under the customised exemption."

But other stakeholders, including some Australian-licensed insurers, have criticised the premium test as subject to the volatility of the market cycle and the variance in insurance taxation across Australia.

Ms Wilkinson accepts there are potential drawbacks.

"The fact the premium test is responsive to the market creates those very problems," she said. "The strength of it is the weakness of it."

The second limb of the DOFI exemptions covers atypical and hard-to-place risks, such as nuclear, satellite and terrorism, while the third limb covers customised exemptions.