This paper describes a concept for subsea coiled tubing well intervention, without the use of a workover riser system. Coiled tubing analyses and design, surface and subsea equipment design, vessel and operational requirements and limitations are addressed.The novel steps in the development are the lubricator system, where the lubricator resides on top of the injector, and the use of a tensioned coiled tubing configuration with a heave compensation system and a second coiled tubing injector at surface.A comparative risk assessment has been performed, and concluded that the overall personell and environmental risk is the same or reduced compared to a workover riser based system.