OPINION AND CONSENT OF COUNSEL

April 11, 2022

Nassau Life Insurance Company

One American Row

P.O. Box 5056

Hartford, CT 06102-5056

Dear Sir/Madam:

With reference to the registration statement filed by Nassau Life Insurance Company (the “Company”) and Nassau Life Variable Accumulation Account (the “Separate Account”) with the Securities and Exchange Commission, file number 811-03488 (the “Registration Statement”), covering variable deferred annuity contracts (the “Contracts”), I have examined such documents and such laws as I considered necessary and appropriate, and on the basis of such examination, it is my opinion that:

1. The Company is duly organized and validly existing under the laws of the State of New York and has been duly authorized to issue variable annuity contracts by the State of New York.

2. The Separate Account is a duly authorized and validly existing separate account pursuant to the laws of the State of New York.

3. Assets allocated to the Separate Account will not be chargeable with liabilities arising out of any other business the Company may conduct.

4. The Contracts have been duly authorized by the Company and, as contemplated by the Registration Statement, constitute legal, validly issued, and binding obligations of the Company.

I hereby consent to the filing of this opinion as an exhibit to the Registration Statement.

Regards,

/s/ Sam S.F. Caligiuri

Sam S.F. Caligiuri

Vice President, Deputy General Counsel and Chief Compliance Officer

Nassau Life Insurance Company