Renewal of Registration of Insurance Web Aggregator

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The Insurance Regulatory and Development Authority of India (IRDAI) mandates a strict and time-bound procedure for the renewal of Insurance Web Aggregator Registration under the Insurance Web Aggregators Regulations. These regulations ensure continued compliance, transparency, and accountability of entities functioning in the insurance distribution ecosystem through online platforms.

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Timeframe and Application Process for Renewal

Renewing the registration of an Insurance Web Aggregator is a crucial regulatory requirement governed by the Insurance Regulatory and Development Authority of India (IRDAI). To ensure business continuity and compliance with regulatory standards, Insurance Web Aggregators must strictly adhere to the renewal timeline and documentation procedure as prescribed under the Insurance Web Aggregator Regulations. The process primarily revolves around timely submission, proper documentation, and compliance with stipulated guidelines.

Submission of Renewal Application

A registered Insurance Web Aggregator is required to submit an application for renewal of its registration to the IRDAI using Form F, which is specified under Schedule II of the Insurance Web Aggregator Regulations. The application must be submitted at least thirty (30) days prior to the expiry of the current certificate of registration. This timeframe is intended to provide the Authority with sufficient time to review, verify, and process the application without interruption in the aggregator's business operations.

To promote timely compliance and avoid last-minute procedural issues, the IRDAI also allows Insurance Web Aggregators to submit the renewal application up to ninety (90) days before the expiry of the registration. This extended window offers flexibility to applicants and ensures that aggregators can plan their submissions well in advance. However, any delay in submission beyond the stipulated 30-day period before expiry may attract penalties or even lead to the suspension of registration if not rectified within permissible limits.

Documents Required for Renewal

Along with the renewal application in Form F, the Insurance Web Aggregator must submit a comprehensive set of supporting documents as prescribed in Form G of Schedule II. These documents serve as proof of continued compliance and operational integrity during the preceding period of registration. While the specific list may vary depending on changes in regulatory requirements, the typical documents required include:

  • Compliance certificates confirming adherence to regulatory norms, code of conduct, and operational standards.

  • Business operation records including details of insurance products solicited, premiums generated, insurer-wise business placement, and customer data management.

  • Declarations regarding the fit and proper status of key managerial personnel such as the Principal Officer and Authorised Verifiers.

  • Statements of financial position, including audited accounts or financial statements indicating the financial health and solvency of the entity.

  • Training completion certificates confirming that the Principal Officer and Authorised Verifiers have undergone renewal training from IRDAI-recognised institutions within the valid timeframe.

Additionally, the Authority may prescribe any other statements, reports, or disclosures as it deems necessary for evaluating the renewal application. It is the responsibility of the applicant to ensure that all documents are complete, current, and accurately reflect the status of operations.

Failure to submit any of the mandatory documents or submission of incorrect or outdated information can lead to delays in processing, rejection of the application, or imposition of penalties. Therefore, meticulous preparation and timely submission of Form G and its enclosures are critical to a successful renewal process. 

Fees and Penalties for Delayed Application

Renewing the registration of an Insurance Web Aggregator is not only subject to regulatory scrutiny but also requires timely financial compliance. The IRDAI has set forth specific provisions relating to renewal fees and late submission penalties to ensure that aggregators remain punctual and responsible in maintaining their registration status. The failure to adhere to prescribed timelines and fee payments may lead to additional charges or even temporary suspension of the aggregator’s operations.

Renewal Fees

As per the IRDAI’s regulations, every application for renewal of the registration of an Insurance Web Aggregator must be accompanied by a non-refundable renewal fee of Rs.25,000, plus applicable Goods and Services Tax (GST) or other taxes as may be prescribed from time to time.

Modes of Payment

The renewal fee can be paid using the following methods:

  • Bank Draft: A demand draft must be drawn in favour of “Insurance Regulatory and Development Authority of India”, payable at Hyderabad.

  • Electronic Funds Transfer: Alternatively, the fee can be remitted via a recognized electronic fund transfer mechanism, such as NEFT/RTGS, to the designated account of IRDAI.

This fee is mandatory and must be paid at the time of filing the renewal application. Failure to include the fee or delays in payment may result in the application being considered incomplete, leading to regulatory action or rejection.

Penalty for Late Submission of Application

To discourage delayed applications, the IRDAI imposes monetary penalties based on how late the renewal application is submitted. These penalties are progressive in nature, depending on the duration of the delay.

Application Submitted Less Than 30 Days Before Expiry

If the renewal application reaches the Authority less than 30 days before the date of expiry of the existing registration, the applicant is required to pay an additional penalty fee of Rs.100. This is a minor penalty intended to ensure that Web Aggregators are conscious of deadlines and submit their applications well in advance.

Application Submitted After Expiry but Within 60 Days

If the application is submitted after the date of expiry but within 60 days from that date, a higher penalty of Rs.750 is applicable. In such cases, the applicant is also required to submit a written explanation providing sufficient reasons for the delay. The Authority, at its discretion, may accept such a delayed application if the justification provided is found satisfactory. However, this window of grace is strictly limited to 60 days beyond the expiry.

This provision is designed to prevent long-standing delays while still giving a limited opportunity for renewal in case of unforeseen circumstances.

Application Submitted Beyond 60 Days of Expiry

Where the renewal application is submitted after 60 days of the expiry, the situation becomes significantly more restrictive. In such cases, the Authority may consider the renewal application only after a lapse of 12 months from the date of expiry of the previous registration.

During this period of 12 months, the Insurance Web Aggregator’s registration is considered null and void, and the entity:

  • Loses its official registration status, and

  • Is prohibited from soliciting new insurance business,

  • Cannot perform any aggregator functions for which the certificate of registration was originally granted.

This restriction acts as a strong deterrent against negligence or continued non-compliance and aims to preserve the sanctity and operational reliability of registered Insurance Web Aggregators in the market. 

Conditions Precedent for Renewal

For an Insurance Web Aggregator to successfully obtain renewal of its registration from the Insurance Regulatory and Development Authority of India (IRDAI), certain pre-conditions must be fulfilled. These prerequisites ensure that the aggregator continues to meet the professional, ethical, and operational standards laid down by the regulatory framework. Renewal is not merely a procedural formality; it is a regulatory checkpoint to evaluate whether the aggregator is fit to continue its operations in the insurance distribution ecosystem.

Valid Training Requirements

One of the fundamental requirements for renewal of registration is the completion of mandatory renewal training by key personnel. As per IRDAI norms, both the Principal Officer and the Authorised Verifiers associated with the Insurance Web Aggregator must undergo renewal training from a training institution recognized by the IRDAI.

Training Timelines and Validity

This training must be completed not earlier than six months before the expiry of the three-year validity of their previous training. In other words, the renewal training must be recent and valid, ensuring that the personnel remain updated with the latest regulatory changes, compliance standards, ethical practices, and technological tools related to insurance web aggregation.

Purpose of the Training

The objective of this requirement is to:

  • Maintain the competence and professionalism of individuals managing aggregator functions.

  • Ensure that aggregators are fully aware of the legal, technical, and operational frameworks in the insurance market.

  • Reduce risks of non-compliance or consumer grievances arising from ignorance or outdated knowledge.

Without the completion of this valid training, the renewal application will not be considered complete and may be rejected or returned for compliance.

Fulfilment of Regulatory Conditions

In addition to training, the Insurance Web Aggregator must satisfy a broad range of regulatory conditions as specified under Regulations 3 and 7 of the Insurance Web Aggregators Regulations. The IRDAI evaluates the aggregator's conduct and compliance history to determine whether the entity remains fit to operate.

Financial Health and Solvency

The aggregator must demonstrate financial soundness by submitting appropriate financial records, including audited financial statements. It should have adequate net worth, liquidity, and solvency margins to continue operations without posing risks to clients or insurers.

Conduct During the Previous Registration Period

The Authority examines whether the aggregator has maintained a record of ethical business conduct during the preceding registration period. Any instances of regulatory violations, consumer complaints, or misconduct will negatively impact the renewal decision.

Compliance with Regulatory Requirements

The aggregator must show proof of adherence to all regulatory and reporting obligations, including:

  • Timely filing of half-yearly returns,

  • Submission of business data insurer-wise,

  • Compliance with advertisement and solicitation guidelines,

  • Following the prescribed code of conduct.

Maintenance of Books of Accounts and Disclosures

The aggregator must have properly maintained books of accounts, registers, and disclosures, as required under the relevant regulations. These include operational records, business transactions, insurer-wise premium placements, and other statutory registers.

The Authority may inspect or audit these records to confirm compliance.

Training and Competence of Personnel

Besides the Principal Officer and Authorised Verifiers, all key staff engaged in solicitation, client communication, or technology must be suitably trained and possess the skills and competence required to discharge their responsibilities. IRDAI emphasizes that the aggregator must maintain a qualified workforce throughout the registration period.

Issue of Renewal Certificate

Once the Insurance Regulatory and Development Authority of India (IRDAI) is satisfied that an Insurance Web Aggregator has fulfilled all regulatory and compliance conditions, it proceeds with the issuance of the renewal certificate. This step signifies the continuation of the aggregator’s authority to conduct insurance business in accordance with the norms established under the Insurance Web Aggregator Regulations. The certificate serves as a legal endorsement of the aggregator’s operational legitimacy for another term.

Grant of Renewal Certificate

Upon verification of the renewal application, supporting documents, payment of fees, and fulfilment of all regulatory preconditions including training, financial compliance, and ethical conduct the Authority will issue a Renewal Certificate of Registration in Form H of Schedule II. This certificate officially extends the validity of the Insurance Web Aggregator’s registration for a further three years from the date of expiry of the previous registration.

This renewed certificate authorizes the Web Aggregator to continue its operations, which include:

  • Soliciting insurance business online,

  • Displaying comparison of products and premiums,

  • Redirecting clients to insurers or licensed insurance intermediaries,

  • Offering value-added digital services as permitted by IRDAI.

Discretion of the Authority in Case of Non-Activity

While the standard procedure mandates renewal upon compliance, the IRDAI retains discretionary powers to refuse the renewal in specific circumstances even when the application is complete. One such situation is where the Authority finds that the Insurance Web Aggregator has been inactive during the entire or part of the previous registration period.

Assessment of Business Activity

If the aggregator has not carried out any insurance business or has shown minimal to no engagement in the web aggregation function, the Authority may interpret this as a lack of genuine interest or inability to perform its mandated role. As a result, it may deny the renewal request, emphasizing that only those entities actively contributing to the insurance ecosystem should hold registration.

Legal Standing of the Renewal Certificate

The renewal certificate issued by IRDAI serves as:

  • A statutory approval to function as a licensed web aggregator,

  • A document of proof to engage with insurers and offer digital insurance comparison and aggregation services,

  • A regulatory record that must be displayed prominently on the aggregator’s website and premises (if any), as part of the transparency mandate.

Failure to obtain or renew this certificate within prescribed timelines will result in loss of legal status, rendering the aggregator ineligible to operate, attract clients, or engage in any solicitation activity.

Refusal to Renew Registration

While the Insurance Regulatory and Development Authority of India (IRDAI) generally grants renewal to Insurance Web Aggregators that comply with all regulatory conditions, it retains the discretionary power to refuse renewal in certain circumstances. This refusal is not arbitrary but is based on well-defined grounds set forth in the regulations, particularly when the aggregator fails to meet the necessary conditions or is found unsuitable to continue operating in the insurance sector.

Grounds for Refusal

According to the Insurance Web Aggregators Regulations, if an application for renewal does not fulfil the conditions prescribed under Regulation 7, the Authority may choose to refuse renewal of the Certificate of Registration. These conditions include:

  • Non-compliance with training or documentation requirements,

  • Failure to submit accurate or complete returns,

  • Financial instability or breach of solvency requirements,

  • Regulatory violations or unethical conduct during the previous term,

  • Lack of business activity or failure to maintain infrastructure and records,

  • Employment of untrained or unauthorized personnel for solicitation.

The refusal to renew is a serious regulatory action taken only when the aggregator's conduct or operations pose a risk to the public interest or undermine the integrity of the insurance distribution ecosystem.

Opportunity of Being Heard

Before arriving at a decision to reject the renewal application, the Authority is bound by principles of natural justice. Therefore, the IRDAI must provide a reasonable opportunity of being heard to the applicant. This means that the aggregator must be given:

  • A written notice or communication outlining the reasons for potential refusal,

  • An opportunity to respond in writing or be heard in person, and

  • The right to submit any explanations, supporting documents, or compliance reports.

Only after this process is followed can the Authority proceed to pass an order refusing renewal.

Communication of Refusal

If the Authority decides to refuse the renewal, it must communicate this decision to the applicant within thirty (30) days from the date of such refusal. The communication must include the specific grounds and justification for the rejection. This ensures transparency and provides the applicant with clarity on the regulatory deficiencies observed by the Authority.

Right to Appeal

In case an applicant is aggrieved by the refusal order, they have the right to challenge it. The applicant may file an appeal before the Securities Appellate Tribunal (SAT) in accordance with the procedure prescribed under the relevant law. The appeal must be filed within forty-five (45) days from the date on which a copy of the refusal order is received.

This appellate mechanism serves as a remedy against wrongful or harsh regulatory decisions and offers the aggregator a fair opportunity to present its case before a judicial forum.

Effect of Refusal to Renew Certificate of Registration

The refusal by the Insurance Regulatory and Development Authority of India (IRDAI) to renew the Certificate of Registration of an Insurance Web Aggregator has serious legal and operational consequences. It directly impacts the aggregator’s ability to continue business and mandates compliance with post-refusal regulatory obligations.

Cessation of Business Activities

Once the renewal of the Certificate of Registration is refused, the concerned Insurance Web Aggregator must immediately cease all web aggregation activities. This includes:

  • Discontinuation of soliciting or sourcing insurance business through the website or digital platforms,

  • Stopping the display of insurance product comparisons or policy-related content,

  • Suspension of any lead generation or advisory services related to insurance policies.

The aggregator is not permitted to conduct any business that falls within the scope of the definition of “Insurance Web Aggregator” under the regulations. Any continuation of such activities would amount to a violation of the IRDAI Act and may attract penal consequences.

Disabling Website Access

One of the foremost requirements after refusal is that the aggregator must disable access to the web portal or online platform through which insurance-related activities were being conducted. The aggregator must:

  • Remove or deactivate any digital interface offering insurance products,

  • Take down price comparison tools, links to insurer websites, or application portals,

  • Ensure no misleading representation that it continues to operate as a registered web aggregator.

This is essential to prevent misleading the public or misrepresenting the aggregator’s regulatory status.

Settlement of Outstanding Obligations

Despite cessation of new business, the aggregator is required to settle all outstanding obligations with insurers, clients, and other stakeholders. This includes:

  • Fulfilling any pending service commitments to customers,

  • Settling payment obligations or commissions with insurance companies,

  • Handing over leads or client records as may be contractually agreed or required by the Authority.

Failure to resolve these matters in a timely manner could lead to regulatory scrutiny or civil liabilities.

Return of Certificate and Compliance with Directions

Within fifteen (15) days of the refusal of renewal, the aggregator is obligated to return the original Certificate of Registration to the IRDAI. Additionally, the aggregator must comply with any specific directions issued by the Authority, which may include:

  • Submission of final business reports or statements,

  • Disclosure of pending litigations or client matters,

  • Cooperation with inspections or audits regarding conduct during the previous registration term.

These measures are designed to ensure proper regulatory closure of the aggregator’s operations.

Prohibition on Reapplication for a Specified Period

In certain cases, especially where refusal is based on serious violations or misconduct, IRDAI may prohibit the applicant from applying for registration again for a specified cooling-off period. The length of this period is decided based on the nature and gravity of the default, and is intended to maintain the integrity and discipline within the insurance distribution sector

Issue of Duplicate Certificate of Registration

Application for Duplicate Certificate

In the event the original certificate is lost, destroyed, or mutilated, an application must be made in Form I (Schedule II), along with:

  • A declaration detailing the circumstances of the loss,

  • A fee of Rs.1,000 plus applicable taxes.

Issue of Duplicate Certificate

Once satisfied, the Authority will issue a duplicate certificate in Form J (Schedule II), clearly endorsed as a duplicate.

Maintenance of Books, Records and Disclosures

Record-Keeping

The guidelines for maintaining books of accounts, operational records, and registers are detailed in Form M (Schedule III). This ensures transparency in the business operations of the aggregator.

Mandatory Disclosures to Authority

Disclosures must be made as per Form N (Schedule III). These include:

  • Half-yearly returns, insurer-wise, for life, general, and health business, submitted by 31st October and 30th April every year.

  • Any additional disclosures or statements as required by the Authority.

IRDAI may issue directions or advisories upon reviewing these disclosures, which must be complied with immediately.

Prohibition on Unregistered Operations

The Insurance Regulatory and Development Authority of India (IRDAI) maintains a strict regulatory framework to ensure that only compliant and eligible entities operate as Insurance Web Aggregators in India. This framework helps preserve the integrity of insurance distribution and protects policyholders from misleading or unauthorised intermediaries. Any operation outside the purview of this regulatory oversight is deemed unlawful and attracts severe legal consequences.

Prohibition on Unauthorized Operation

Under the IRDAI (Insurance Web Aggregators) Regulations, it is explicitly prohibited for any individual, partnership firm, company, or other entity to function as a Web Aggregator without holding a valid Certificate of Registration issued by the Authority. The prohibition also extends to digital platforms, websites, or portals that attempt to provide insurance-related information, price comparisons, lead generation, or any such activity without being duly registered.

In addition, insurance companies are also barred from entering into agreements or carrying out business transactions with unregistered or unauthorized web aggregators. Insurers must conduct due diligence to ensure that their digital distribution partners are compliant with IRDAI regulations, and failure to do so could also invite regulatory action against the insurer.

Penal and Legal Action

The consequences of operating without registration are stringent and multi-faceted. Any individual or entity found to be acting as a Web Aggregator without IRDAI’s approval is liable to face criminal prosecution under the relevant provisions of the law, including the Insurance Act, 1938, the IRDAI Act, 1999, and Information Technology laws (where digital media is involved).

Penalties may include:

  • Imposition of monetary fines by the IRDAI,

  • Suspension or cancellation of any other insurance-related license the violator may hold,

  • Institution of criminal proceedings for fraud, misrepresentation, or violation of regulatory mandates,

  • Civil liability, including compensation claims by affected clients or insurers.

The severity of the penalty is determined by the gravity of the offence, the intent of the violator, and the quantum of harm or risk posed to the public or the insurance ecosystem.

Liability of Officers and Partners

When the offence of unauthorised operation is committed by a company, partnership firm, LLP, or any other corporate entity, the liability is not limited to the business entity alone. Under the principle of vicarious and personal liability, every individual who are responsible for the conduct of the business at the time of such contravention shall be held personally accountable.

This includes:

  • Managing Directors and Executive Directors,

  • Chief Executive Officers and Principal Officers,

  • Partners in the case of partnership firms or LLPs,

  • Any person who has knowingly permitted, directed, or participated in such unauthorised activity.

Such individuals may face independent legal proceedings and regulatory sanctions, including disqualification from holding office in future insurance intermediary roles.

Conclusion

The renewal of registration for Insurance Web Aggregators is a meticulous process, regulated to ensure transparency, consumer protection, and ethical standards in the digital insurance marketplace. Strict adherence to timelines, training requirements, disclosures, and compliance with IRDAI norms is essential for uninterrupted operations. Any failure to renew on time or meet regulatory expectations can lead to suspension, penalties, or cancellation of the license, severely impacting business continuity. 

Frequently Asked Questions (FAQs) 

Q1. When should an Insurance Web Aggregator apply for renewal of registration?

Ans. An IWA must apply for renewal at least 30 days before the expiry of the existing registration. However, IRDAI allows late submission up to the expiry date, subject to a late fee of Rs.100 per day.

Q2. What is the validity period of an IWA Certificate of Registration?

Ans. The Certificate of Registration is valid for three (3) years from the date of issuance. Renewal is required every three years to continue operations legally.

Q3. In which form should the renewal application be submitted?

Ans. The renewal application must be submitted in Form F as specified in Schedule I of the IRDAI (Insurance Web Aggregators) Regulations, 2017, along with the required supporting documents.

Q4. What documents are required to be attached with the renewal application?

Ans. Key documents include:

  • Duly filled Form F (Application for Renewal)

  • Self-certified copies of financial statements for the past three years

  • Updated “Fit & Proper” declarations (Form D)

  • Training completion certificates for the Principal Officer and Authorised Verifiers

  • Compliance report on business operations and statutory filings

  • Proof of capital adequacy and infrastructure

  • Details of grievance redressal and consumer complaints

Q5. Is there any fee for renewal of IWA registration?

Ans. Yes. A non-refundable renewal fee of Rs.25,000 must be paid along with the application. Late submission (after the 30-day window) attracts an additional Rs.100 per day up to the date of expiry.

Q6. What are the training requirements for renewal?

Ans. The Principal Officer and Authorised Verifiers must undergo refresher training at an IRDAI-approved institute within six months prior to the expiry of the current registration. This is mandatory for renewal consideration.

Q7. What happens if an IWA misses the renewal deadline?

Ans. If the IWA fails to apply for renewal before the registration expiry date, it may result in automatic lapse of the registration. The entity must then cease operations and may need to reapply afresh for a new license.

Q8. Can IRDAI reject a renewal application? On what grounds?

Ans. Yes. IRDAI may reject a renewal application on the following grounds:

  • Failure to meet financial and solvency standards

  • Non-compliance with reporting obligations (Forms L and M)

  • Significant consumer complaints or regulatory action

  • Failure to undergo required training

  • Submission of incomplete or false information

  • Engaging in prohibited practices (e.g., solicitation or advertisements)

Q9. Is an on-site inspection or audit mandatory before renewal?

Ans. While not mandatory in all cases, IRDAI may conduct inspections or ask for clarifications if the aggregator has a history of non-compliance, operational lapses, or complaints during the preceding term.

Q10. What is the role of Form M and Form L in the renewal process?

Ans. IWAs must have filed periodic returns during the registration period:

  • Form L – Half-yearly business returns

  • Form M – Annual statement of business, grievance records, lead sources, etc.

    Timely and accurate filing of these forms is a condition for renewal approval. 

Q11. How does IRDAI assess “ethical conduct” for renewal eligibility?

Ans. IRDAI evaluates ethical conduct based on:

  • Complaint resolution history

  • Use of fair practices in digital operations

  • Absence of solicitation or misleading content

  • Transparency in lead handling

  • Proper disclosures to consumers

Q12. How long does it take IRDAI to process the renewal application?

Ans. If all documents are in order, IRDAI typically processes the renewal application within 30 to 60 days. However, delays may occur if clarifications, inspections, or rectifications are needed.

Q13. Can an IWA continue business after the expiry date while renewal is under process?

Ans. No. If the Certificate of Registration has expired and renewal is pending, the IWA must temporarily cease operations until a new or renewed certificate is issued. Operating during this gap period is a regulatory violation.

Q14. Is there any penalty for non-compliance discovered during renewal assessment?

Ans. Yes. If IRDAI finds violations such as failure to maintain records, misreporting, or unethical conduct, it may impose penalties, suspend registration, or deny renewal outright.

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