Insurance Marketing Firm (IMF) Registration in India – IRDAI License

Eligibility Criteria for IMF Registration

Before applying for Insurance Marketing Firm Registration, the proposed structure should be evaluated against IRDAI's eligibility, financial, management and infrastructure requirements. Compliance Calendar LLP generally recommends completing an eligibility assessment before incorporation so that avoidable restructuring is not required later.

Eligible Entity

An Insurance Marketing Firm may be established through an eligible legal form recognised under the IMF Regulations, including:

• a Company incorporated under the Companies Act;

• a Limited Liability Partnership;

• an eligible Co-operative Society; or

• another person/entity recognised by IRDAI for this purpose.

The appropriate structure should be selected after considering ownership, governance, investment plans, taxation and the long-term business model.

Minimum Net Worth

The current IMF Regulations provide for net worth of:

• Rs. 5 lakh where the applicant opts only for one district which is an aspirational district; and
• Rs. 10 lakh in other cases.

The 2026 amendment continues the special Rs. 5 lakh net-worth provision for an applicant opting for only one aspirational district. For most applicants planning a wider operation, the Rs. 10 lakh net-worth requirement should therefore be considered at the structuring stage. The prescribed net worth is required to be maintained on a continuing basis.

Area of Operation

An important regulatory change was introduced through the IRDAI Insurance Intermediaries Amendment Regulations, 2022. The regulatory definition of "Area" was changed to the State for which the IMF Registration is valid, and registered IMFs may operate in all districts within that State. This is important because several older online articles and even older FAQ material continue to refer to the previous three-district framework.

Fit and Proper Criteria

Promoters, directors, partners, the Principal Officer and other relevant persons should meet applicable fit-and-proper requirements.

IRDAI may consider matters such as:

• integrity;

• financial soundness;

• regulatory history;

• professional conduct;

• past convictions or proceedings;

• competence; and

• suitability for carrying on insurance-intermediary activities.

Infrastructure

The IMF should have infrastructure proportionate to its proposed scale of operations, including:

• appropriate office premises;

• computers and IT systems;

• internet and communication facilities;

• adequate manpower;

• secure records;

• customer-service capability; and

• operational processes.

Infrastructure information and photographs can form part of the regulatory application.

Business Plan

An IMF applicant is required to prepare a three-year business plan explaining the proposed operations and financial projections.

A well-prepared business plan should cover:

• proposed insurance business;

• target customers;

• insurer relationships;

• State/market strategy;

• manpower;

• PO and ISPs;

• customer acquisition;

• technology;

• infrastructure;

• projected premium/business volume;

• projected revenue and expenses;

• compliance structure; and

• financial projections.

You can refer to our detailed guide on preparing a business plan for an IRDAI intermediary licence application.

Activities Permitted to an Insurance Marketing Firm

An IRDAI-registered Insurance Marketing Firm can carry out insurance-distribution and related activities within the scope of its registration and the applicable regulatory framework.

Insurance Distribution

The core activity of an IMF is solicitation and procurement of insurance products through qualified Insurance Sales Persons.

Following the 2022 amendment, an IMF can engage ISPs for soliciting and procuring products of up to:

• 6 Life Insurers

• 6 General Insurers

• 6 Health Insurers

Accordingly, an IMF can potentially establish arrangements with up to 18 insurers across the three lines of business, subject to regulatory requirements and intimation to IRDAI.

This expanded open-architecture framework is one of the significant commercial advantages of an IMF structure.

Change in Insurer Tie-Ups

Where there is an addition, termination or discontinuation of an insurer relationship, the IMF must comply with the agreement governing the relationship and ensure suitable arrangements for servicing existing policyholders. Changes in insurer engagements are also required to be intimated to IRDAI in the prescribed manner.

Insurance Products

An IMF may distribute insurance products permitted under the applicable regulatory framework and its arrangements with insurers.

Depending upon the relevant permissions and insurer portfolio, this may cover products in:

• Life Insurance;

• General Insurance;

• Health Insurance; and

• eligible retail and other permitted insurance categories.

Insurance Servicing Activities

An IMF may also undertake permitted insurance servicing activities where the activity is covered under its regulatory framework and arrangements.

Where such activities form part of the proposed business model, they should be clearly reflected in the:

• Form A;

• business plan;

• organisational structure;

• infrastructure; and

• manpower plan.

Other Financial Products

One of the distinguishing features of the Insurance Marketing Firm model is its ability to distribute specified non-insurance financial products through appropriately qualified and authorised Financial Services Executives (FSEs). The authorisation to distribute such products is governed by the concerned financial-sector regulator. Accordingly, IMF Registration should not be treated as an automatic authorisation to distribute every financial product.

Distance Marketing

An IMF may undertake distance marketing subject to applicable IRDAI requirements, including regulatory approval and use of authorised personnel. The IMF should therefore design its digital sales and marketing framework with insurance-distribution regulations in mind rather than treating online solicitation as an unrestricted activity.

Principal Officer, ISP and FSE Requirements for IMF Registration

People and regulatory competency are important parts of an IRDAI IMF Registration application. The key personnel typically include the Principal Officer, Insurance Sales Persons and, where applicable, Financial Services Executives.

Principal Officer

• Every IMF must have an eligible Principal Officer (PO).
• The Principal Officer is responsible for oversight of the Insurance Marketing Firm's activities and regulatory compliance.
• The proposed PO should therefore be selected before the final IMF application is prepared.

Principal Officer Eligibility

• The Principal Officer must fulfil an eligibility route recognised under the applicable IMF Regulations.
• Recognised qualifications and experience routes include prescribed insurance, actuarial, risk-management and professional qualifications, as well as certain graduate and management qualifications combined with relevant insurance or financial-services experience.

Professional qualifications recognised under the framework include, subject to applicable conditions, qualifications from institutions such as:

• Insurance Institute of India;

• Institute of Actuaries of India;

• Chartered Insurance Institute;

• Institute of Insurance and Risk Management;

• ICAI;

• ICMAI; and

• ICSI.

The eligibility of the proposed Principal Officer should always be examined against his or her actual qualification and experience. For greater detail, refer to our guide on Principal Officer eligibility and examination for an Insurance Marketing Firm.

Principal Officer Training

The proposed Principal Officer is required to complete the prescribed training and pass the required examination, subject to the applicable eligibility and exemption framework.

New Continuing Training Requirement

A significant change introduced in 2026 is the requirement that the Principal Officer and all Insurance Sales Persons complete at least 25 hours of training once every three years through an examination body recognised by IRDAI. This should now form part of every IMF's compliance calendar.

Insurance Sales Person

An Insurance Sales Person (ISP) is engaged by an IMF for solicitation and procurement of insurance business.

The ISP must satisfy the applicable:

• eligibility criteria;

• educational qualification;

• training requirement;

• examination requirement;

• residency requirement; and

• regulatory conditions.

An IMF should maintain proper records of its ISPs and ensure that only duly qualified and compliant personnel undertake solicitation.

Financial Services Executive

• A Financial Services Executive (FSE) is engaged for distribution of eligible non-insurance financial products.
• An FSE must possess the licence, registration, certification or authorisation prescribed by the regulator governing the relevant product.
• An individual may perform more than one permitted role only where all requirements applicable to each role are independently satisfied.

Documents Required for IMF Registration

The exact IMF Registration document checklist varies depending upon the legal structure, promoters, Principal Officer, proposed activities and specific information sought by IRDAI.

Entity Documents

• Certificate of Incorporation or registration;

• Memorandum of Association;

• Articles of Association;

• LLP Agreement, where applicable;

• PAN of the applicant;

• registered-office documents;

• constitutional documents;

• appropriate regulatory objects;

• corporate authorisations; and

• IRDAI NOC-related documents.

Promoter / Director / Partner Documents

These can include:

• PAN;

• identity proof;

• address proof;

• photographs;

• background particulars;

• shareholding/contribution details;

• regulatory declarations; and

• fit-and-proper declarations.

Principal Officer Documents

The Principal Officer documentation commonly includes:

• PAN and identity documents;

• address proof;

• educational qualification certificates;

• professional certificates;

• experience certificates;

• IMF examination certificate;

• training documents;

• fit-and-proper declaration; and

• prescribed undertaking.

ISP Documents

Depending upon the application, ISP documentation may include:

• identity proof;

• address/residence proof;

• qualification documents;

• training certificate;

• examination certificate; and

• employment/engagement particulars.

Financial Documents

Financial documentation may include:

• CA-certified Net Worth Certificate;

• applicant's bank statement supporting net worth;

• financial statements, where applicable;

• source/funding information; and

• additional financial clarification required by IRDAI.

Operational Documents

These generally include:

• three-year business plan;

• organisation chart;

• functional responsibilities;

• infrastructure details;

• office proof;

• lease deed or ownership document;

• office photographs;

• equipment details;

• manpower plan; and

• projected business and income.

IRDAI's registration guidance specifically calls for a three-year business plan, organisation chart, infrastructure details and net-worth evidence.

Insurer Consent

The applicant is also required to submit consent from insurance companies with whom it proposes to work. Current IRDAI application guidance states that at least one insurer consent letter is necessary as part of the IMF registration application.

Why Consistency Matters

IRDAI can compare information appearing across:

• MCA records;

• constitutional documents;

• Form A;

• PO documents;

• ISP details;

• Net Worth Certificate;

• bank statements;

• business plan;

• organisation chart;

• insurer consent; and

• infrastructure records.

For this reason, an IMF application should be prepared as one integrated regulatory file, not as independent sets of documents prepared without cross-checking.

Step-by-Step IMF Registration Process with IRDAI

The Insurance Marketing Firm Registration process involves both corporate-registration and IRDAI-regulatory stages.

Step 1 – Regulatory Assessment

The first stage should determine:

• appropriate legal entity;

• proposed promoters;

• Principal Officer;

• State/area strategy;

• insurer categories;

• net-worth requirement;

• manpower;

• office structure; and

• business model.

Step 2 – Proposed IMF Name

• The proposed name should comply with the applicable IRDAI and MCA requirements.
• The name should appropriately reflect the proposed Insurance Marketing Firm activity and must not conflict with an existing regulated entity or applicable naming restrictions.

Step 3 – IRDAI NOC

• Apply for the IRDAI NOC for the proposed IMF name.
• IRDAI's IMF department is responsible for issuance of the NOC enabling the proposed entity to proceed with registration before the Registrar of Companies.

Step 4 – Company / LLP Incorporation

• After receipt of the NOC, the applicant proceeds with incorporation/registration of the proposed legal entity.
• The constitutional documents should contain appropriate objects consistent with the intended Insurance Marketing Firm activities.

Step 5 – Principal Officer Readiness

Review and complete the PO's:

• qualification;

• experience;

• training;

• examination;

• fit-and-proper; and

• supporting documents.

Step 6 – ISP Readiness

• Identify and prepare the Insurance Sales Persons required for the proposed operation.

Step 7 – Net Worth

Ensure that the applicable net worth is maintained and supported through:

• appropriate banking records; and

• Chartered Accountant certification.

Step 8 – Infrastructure

• Set up the proposed office, manpower and operational infrastructure and maintain the supporting documents required for the application.

Step 9 – Insurer Consent

• Obtain the insurer consent documentation required for filing the IMF Registration application.
• IRDAI currently requires at least one consent letter to accompany the registration application.

Step 10 – Three-Year Business Plan

• Prepare the business plan covering proposed business volume, income projections, organisation structure, insurer strategy, market plan, manpower and financial projections.
• Our guide on preparing an IRDAI intermediary business plan explains this requirement in more detail.

Step 11 – Form A

• Complete and submit Form A for IMF Registration through the prescribed IRDAI mechanism along with supporting documents.

Step 12 – Application Fee

• The IRDAI (Insurance Intermediaries) (Amendment) Regulations, 2026 prescribe a non-refundable IMF application fee of Rs. 10,000.

Step 13 – IRDAI Scrutiny

IRDAI may examine:

• applicant eligibility;

• promoters;

• Principal Officer;

• ISPs;

• business plan;

• net worth;

• infrastructure;

• insurer consent;

• regulatory declarations;

• fit-and-proper status; and

• overall operational readiness.

Step 14 – Query Handling

• IRDAI may seek additional information, explanations or documentation.
• Any response should remain consistent with the original Form A and supporting documents.

Step 15 – Grant of Registration

Once the Authority is satisfied with the application and prescribed fee requirements are complied with, it may issue the Certificate of Registration as an Insurance Marketing Firm. Under the current framework, the registration remains in force subject to payment of annual fees unless suspended, cancelled or surrendered.

IMF Registration Fees and Timeline

Understanding the regulatory cost structure is important before starting an IRDAI IMF Registration.

IRDAI Application Fee

• The current non-refundable application fee for a fresh IMF Registration is Rs. 10,000
• The fee structure was revised through the IRDAI (Insurance Intermediaries) (Amendment) Regulations, 2026.

This is separate from:

• incorporation expenses;

• MCA fees and stamp duty;

• professional fees;

• PO training/examination;

• ISP training/examination;

• CA certification;

• office infrastructure;

• Professional Indemnity Insurance; and

• other regulatory or operational costs.

Annual Regulatory Fee

After registration, an IMF is required to pay an annual fee. The annual fee is the higher of Rs. 10,000; or one-twenty-fifth of one per cent of commission and other receipts from insurers during the relevant preceding financial year, rounded to the next thousand. One-twenty-fifth of one per cent is equivalent to 0.04%. The annual-fee mechanism forms part of Schedule XI introduced through the 2026 amendment.

Annual Fee Due Date

The annual fee for every financial year is required to be paid before 31 January of the preceding financial year, subject to the applicable regulations.

Delay in Annual Fee

The 2026 framework provides additional charges where payment is delayed.

Broadly:

• delay within the first 30 days attracts an additional 2% of the annual fee; and

• a longer delay within the permitted period attracts an additional 10% of the annual fee.

Continued non-payment can expose the registration to suspension or cancellation.

IMF Registration Timeline

There is no responsible way to guarantee one fixed timeline for every IMF Registration.

The total timeline depends upon matters such as:

• NOC;

• incorporation;

• Principal Officer readiness;

• training and examination;

• ISP readiness;

• net-worth arrangement;

• insurer consent;

• business-plan preparation;

• application completeness;

• IRDAI scrutiny; and

• regulatory queries.

A well-prepared application generally avoids delays caused by preventable documentation or eligibility issues.

IMF Annual Compliance under the 2026 Framework

The regulatory focus for Insurance Marketing Firms has shifted from periodic licence renewal to continuing registration supported by ongoing compliance and annual regulatory fees. Under the 2026 amendment, once issued, an IMF Registration remains in force subject to payment of the applicable annual fee until it is suspended, cancelled or surrendered. For a detailed explanation, read our article on IRDAI 2026 changes for Insurance Marketing Firms.

Annual Fee Compliance

Every IMF should track:

• annual fee computation;

• commission and relevant receipts;

• prescribed payment date;

• proof of electronic payment; and

• applicable additional fee where payment is delayed.

Net Worth

• The applicable minimum net worth must be maintained continuously.
• The IMF should also maintain the prescribed Chartered Accountant certification and supporting financial records.

Continuous Training

• The 2026 amendment introduced an important continuing-training requirement.
• The Principal Officer and all ISPs are required to complete at least 25 hours of training once every three years through an examination body recognised by IRDAI.

Professional Indemnity Insurance

The IMF should maintain Professional Indemnity Insurance in accordance with the applicable IMF Regulations and ensure continuity of coverage.

Records

A registered IMF should maintain applicable records relating to:

• customers;

• proposals;

• policies;

• premiums;

• remuneration;

• insurer relationships;

• ISPs;

• complaints;

• KYC;

• regulatory correspondence; and

• other prescribed information.

Regulatory Returns and Information

• IRDAI may require IMFs to submit reports, information and returns in the form and manner specified by the Authority.
• Accordingly, post-registration compliance should be handled through a structured compliance calendar rather than only when an IRDAI communication is received.
• Our broader guide on IRDAI compliance requirements for insurance intermediaries discusses the importance of ongoing compliance after registration.

Changes after IMF Registration

Changes involving matters such as:

• Principal Officer;

• shareholding;

• registered/operating address;

• management;

• insurer relationships; and

• other material registration particulars

should be reviewed for prior approval or intimation requirements before implementation.

IRDAI's IMF department specifically handles post-registration permissions for matters such as shareholding, Principal Officer and address changes.

Important Transition for Existing IMFs

An IMF registered before commencement of the 2026 amendment with an existing three-year Certificate of Registration is required to apply for issuance of a fresh Certificate of Registration under the new framework before 31 January 2027. A delayed application may be considered up to 31 March 2027, subject to the prescribed conditions and an additional fee of Rs. 750.

Where the required application is not made by 31 March 2027, the IMF will need to proceed under the fresh-registration framework.

Insurance Marketing Firm vs Insurance Broker

Both an Insurance Marketing Firm and an Insurance Broker are regulated by IRDAI, but the business models and regulatory frameworks are different.

For a more detailed understanding, read our analysis of the difference between an Insurance Broker and an Insurance Marketing Firm.

Choosing the Appropriate Model

The appropriate intermediary model should be selected after considering:

• insurer relationships required;

• target customers;

• retail or commercial insurance focus;

• geographical strategy;

• product categories;

• available capital;

• manpower;

• technology;

• revenue model;

• advisory requirements; and

• long-term scale.

A promoter planning a structured distribution model within the IMF framework may consider an IMF, whereas a business intending to undertake insurance broking should evaluate the separate Insurance Broker Regulations. The structure should ideally be determined before incorporation and regulatory expenditure.

Why Choose Compliance Calendar LLP for IMF Registration?

Insurance Marketing Firm Registration is a specialised regulatory assignment involving a combination of IRDAI regulations, corporate law, financial documentation, Principal Officer requirements, insurer coordination and post-registration compliance. Compliance Calendar LLP provides an integrated approach to the entire process.

100+ IMF Registration Assignments

We have handled more than 100 IMF Registration assignments, giving our team practical exposure across multiple stages of the regulatory process.

Our experience covers areas such as:

• eligibility evaluation;

• IMF business-model structuring;

• IRDAI NOC;

• incorporation;

• object-clause drafting;

• Principal Officer eligibility;

• training and examination documentation;

• ISP readiness;

• net worth;

• insurer consent;

• business-plan preparation;

• Form A;

• infrastructure documentation;

• IRDAI queries;

• regulatory clarifications;

• registration;

• changes after registration; and

• annual compliance.

Regulatory and Corporate Expertise

An IMF applicant must comply not only with IRDAI requirements but also with the corporate-law framework applicable to the underlying Company or LLP.

Our work therefore considers both:

• IRDAI regulatory compliance, and
• MCA / Companies Act / LLP compliance.

This helps prevent inconsistencies between corporate records and the information submitted to IRDAI.

IMF Application Readiness

We do not view IMF Registration merely as filing Form A.

A properly prepared regulatory application should clearly explain:

• who the promoters are;

• why the IMF is being established;

• who will act as Principal Officer;

• how the PO is eligible;

• who will act as ISPs;

• which State will be covered;

• which insurers are proposed;

• how the applicant is funded;

• whether net worth is maintained;

• what infrastructure exists;

• how the IMF proposes to earn revenue;

• how customers will be serviced; and

• how ongoing compliance will be maintained.

End-to-End IMF Support

Our IMF Registration scope can cover:

1. Eligibility Review – Business structure, promoters, PO and regulatory readiness.

2. IRDAI NOC – Assistance with the proposed IMF name and NOC process.

3. Incorporation – Company/LLP registration with appropriate objects.

4. PO & ISP – Qualification, training and documentation support.

5. Net Worth – Coordination of required financial documentation.

6. Insurer Consent – Documentation and regulatory guidance.

7. Business Plan – Preparation/review of the three-year regulatory business plan.

8. Form A – Application preparation and filing support.

9. IRDAI Queries – Drafting and submission assistance for clarifications.

10. Compliance – Support after registration, including corporate and IRDAI matters.

Current Regulatory Understanding

The insurance intermediary framework has changed materially in 2026.

Our approach incorporates the current requirements relating to:

• continuing registration;

• annual regulatory fees;

• new application fees;

• ongoing PO/ISP training;

• transition of existing registrations; and

• continuing regulatory reporting.

This practical regulatory approach is particularly important where older online material still reflects the previous IMF framework. Planning to obtain an IRDAI Insurance Marketing Firm Registration? Connect with the regulatory team at Compliance Calendar LLP for eligibility assessment and end-to-end registration support.