Role of ISP vs PoSP under IRDAI guidelines

Role of ISP vs PoSP under IRDAI guidelines. In the Indian insurance distribution ecosystem, distinct regulatory models play a major role and the Insurance Regulatory and Development Authority of India (IRDAI) has created multiple distribution channels to increase insurance penetration across the country. 
Two important roles within these channels are Insurance Sales Person (ISP) under the Insurance Marketing Firm (IMF) model and Point of Sales Person (PoSP) under the Insurance Broker Company/Corporate Agency model.
Although both ISPs and PoSPs are responsible for selling insurance products, their regulatory frameworks, training requirements, and operational scopes are entirely different.
Many firms and compliance professionals often ask:
If I have an IMF registration, can I appoint PoSPs?
The short answer is No as not under the IMF regime as it currently stands. But this answer deserves unpacking. Let’s explore why the two models differ, how each is regulated, and what strategic options exist for entities seeking to combine their benefits.
IMFs are licensed as corporate intermediaries, accountable for their ISPs’ conduct. Therefore, PoSPs are registered under insurers or intermediaries authorised to use that channel. If an IMF appointed PoSPs, it would effectively act as a broker or corporate agent and something the IMF license does not allow.
ISP: Insurance Sales Person (Under IMF Model)

Governed by: IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015.

Associated with: Insurance Marketing Firm (IMF).

Licensing Entity: IMF, which employs or appoints ISPs to solicit insurance business.

Eligibility & Appointment
An ISP is an individual appointed by an IMF to solicit insurance business on behalf of the IMF and the appointment is subject to training and registration with IRDAI through the IMF.
Training Requirements

Freshers: 50 hours of training.

Experienced personnel (with existing insurance certification): 25 hours.

Training covers insurance products, customer handling, and compliance under IMF regulations.

Scope of Activities
An ISP can solicit business for:

One Life Insurer

One General or Health Insurer

One Standalone Health Insurer

And ISPs work exclusively under the IMF and follow its code of conduct and operational limits.
Remuneration/ Salary
ISPs are employees of the IMF and must receive a fixed monthly salary and it does  not less than Rs.5,000 as per latest IRDAI amendment and Commission-based income structures are not allowed for ISPs.
Compliance & Reporting
The IMF must maintain:

Registers of ISPs and their training details.

Salary records and returns filed with IRDAI.

Proper Board approvals and reporting structure.

PoSP: Point of Sales Person (Under Broker/Corporate Agent Model)
PoSP Governed by the IRDAI (Protection of Policyholders’ Interests and Allied Matters) Regulations, 2017, and IRDAI Guidelines on Point of Sales Products and Persons – Life, General & Health Insurance which is associated with: Insurance Broker, Corporate Agent, or Insurer.
Eligibility & Appointment
A PoSP is an individual authorised by an insurer, broker, or corporate agent to sell simple, pre-approved insurance products. The appointment of PoSP happens under a contractual relationship and it is not an employment.
Training Requirements
Minimum 15 hours of IRDAI-approved training (online or in-person) for each product category and PoSPs must pass an examination conducted by the appointing intermediary or insurer.
Scope of Activities
PoSPs can sell pre-defined and simple retail products, such as:

Term life policies

Motor insurance

Personal accident insurance

Health insurance with limited benefits

And PoSPs are limited to selling for one intermediary/insurer at a time.
Remuneration
PoSPs are generally paid commission or incentive-based remuneration, as per contract terms with the appointing entity.
Compliance & Reporting
Insurers or intermediaries employing PoSPs must:

Maintain half-yearly returns to IRDAI.

Keep PoSP training, KYC, and product sales records.

Ensure that the PoSP adheres to the code of conduct and product restrictions.

Difference between ISP vs PoSP

Parameter

ISP (Insurance Sales Person)

PoSP (Point of Sales Person)

Regulatory Basis

IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015

IRDAI PoSP Guidelines, 2017 + Broker/Agent Regulations

Associated Entity

Insurance Marketing Firm (IMF)

Broker / Corporate Agent / Insurer

Employment Nature

Employee or appointed representative of IMF

Contractual associate of insurer/intermediary

Training Hours

50 (freshers) / 25 (experienced)

15 hours per product line

Certification

Conducted by IRDAI-recognized training institution via IMF

Conducted by insurer/intermediary through IRDAI-approved module

Remuneration Type

Fixed monthly salary (minimum Rs.5,000)

Commission or incentive-based

Product Scope

Life, general, and health products of tied-up insurers

Simple retail insurance products only

Tie-up Limit

One life, one general/health, one standalone health insurer

One intermediary or insurer at a time

Reporting Authority

IMF to IRDAI

Insurer/intermediary to IRDAI

Model Type

Institutional, compliance-heavy, long-term

Retail, flexible, quick-deployment

Objective

Enhance professional, advisory-driven insurance sales

Expand retail outreach for simple products

Why Cannot Appoint a PoSPs under the IMF model ?
Under the current IRDAI regulatory structure, the Insurance Marketing Firm (IMF) company  and Point of Sales Person (PoSP) models operate under two distinct sets of rules designed for different segments of insurance distribution.
The IMF channel is governed by the IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015, which authorize IMFs to appoint and manage Insurance Sales Persons (ISPs) for soliciting insurance business. These ISPs are trained, certified, and salaried representatives who work exclusively under the IMF’s supervision.
In contrast, the PoSP structure is established under separate IRDAI guidelines applicable to insurers, brokers, and corporate agents. PoSPs function as independent, contract-based representatives who are permitted to sell simple, pre-approved insurance products after completing limited training and certification.
Since the IMF Regulations, 2015, contain no provision authorizing an IMF to appoint PoSPs, any such engagement would be non-compliant with IRDAI norms. IMFs are therefore restricted to operating only through ISPs registered under their own license.
How Compliance Calendar LLP Helps You Achieve Smooth IMF and Insurance Broker Registration
At Compliance Calendar LLP, we simplify the tedious regulatory journey of obtaining IRDAI registration and whether you are setting up an Insurance Marketing Firm (IMF) or an Insurance Broker Company. Our expert team of Company Secretaries, Chartered Accountants, and IRDAI compliance professionals allows you that every step of your application is executed with precision and in full adherence to the latest IRDAI guidelines.
From entity structuring to choose LLP registration or Private Limited Company including capital verification to drafting the business plan, LOIs from insurers, Principal Officer training, fit & proper declarations, and documentation in Form A, we manage the process end-to-end. We also assist with infrastructure readiness, compliance checklists, including IRDAI Broker or IMF Exam & Training guide and coordination with IRDAI officials until the registration certificate is successfully granted.
We at Compliance Calendar LLP, our experience with multiple clients across India allows us to anticipate common challenges whether it’s drafting the Letter of Intent (LOI) for insurers in case of IMF applications or meeting the net-worth, deposit, and personnel criteria under the IRDAI (Insurance Brokers) Regulations, 2018. We handle every procedural requirement so that you can focus on building your insurance distribution business confidently.
With Compliance Calendar LLP, your company  registration process becomes seamless, transparent, and fully compliant with IRDAI’s expectations. From advisory to post-licensing compliance with MCA and IRDAI, We here act as your trusted partner in turning your insurance distribution vision into reality.

In the Indian insurance distribution ecosystem, distinct regulatory models play a major role and the Insurance Regulatory and Development Authority of India (IRDAI) has created multiple distribution channels to increase insurance penetration across the country.

Two important roles within these channels are Insurance Sales Person (ISP) under the Insurance Marketing Firm (IMF) model and Point of Sales Person (PoSP) under the Insurance Broker Company/Corporate Agency model.

Although both ISPs and PoSPs are responsible for selling insurance products, their regulatory frameworks, training requirements, and operational scopes are entirely different.

Many firms and compliance professionals often ask:

If I have an IMF registration, can I appoint PoSPs?

The short answer is No as not under the IMF regime as it currently stands. But this answer deserves unpacking. Let’s explore why the two models differ, how each is regulated, and what strategic options exist for entities seeking to combine their benefits.

IMFs are licensed as corporate intermediaries, accountable for their ISPs’ conduct. Therefore, PoSPs are registered under insurers or intermediaries authorised to use that channel. If an IMF appointed PoSPs, it would effectively act as a broker or corporate agent and something the IMF license does not allow.

ISP: Insurance Sales Person (Under IMF Model)

Governed by: IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015.
Associated with: Insurance Marketing Firm (IMF).
Licensing Entity: IMF, which employs or appoints ISPs to solicit insurance business.

Eligibility & Appointment

An ISP is an individual appointed by an IMF to solicit insurance business on behalf of the IMF and the appointment is subject to training and registration with IRDAI through the IMF.

Training Requirements

Freshers: 50 hours of training.
Experienced personnel (with existing insurance certification): 25 hours.
Training covers insurance products, customer handling, and compliance under IMF regulations.

Scope of Activities

An ISP can solicit business for:

One Life Insurer
One General or Health Insurer
One Standalone Health Insurer

And ISPs work exclusively under the IMF and follow its code of conduct and operational limits.

Remuneration/ Salary

ISPs are employees of the IMF and must receive a fixed monthly salary and it does not less than Rs.5,000 as per latest IRDAI amendment and Commission-based income structures are not allowed for ISPs.

Compliance & Reporting

The IMF must maintain:

Registers of ISPs and their training details.
Salary records and returns filed with IRDAI.
Proper Board approvals and reporting structure.

PoSP: Point of Sales Person (Under Broker/Corporate Agent Model)

PoSP Governed by the IRDAI (Protection of Policyholders’ Interests and Allied Matters) Regulations, 2017, and IRDAI Guidelines on Point of Sales Products and Persons – Life, General & Health Insurance which is associated with: Insurance Broker, Corporate Agent, or Insurer.

Eligibility & Appointment

A PoSP is an individual authorised by an insurer, broker, or corporate agent to sell simple, pre-approved insurance products. The appointment of PoSP happens under a contractual relationship and it is not an employment.

Training Requirements

Minimum 15 hours of IRDAI-approved training (online or in-person) for each product category and PoSPs must pass an examination conducted by the appointing intermediary or insurer.

Scope of Activities

PoSPs can sell pre-defined and simple retail products, such as:

Term life policies
Motor insurance
Personal accident insurance
Health insurance with limited benefits

And PoSPs are limited to selling for one intermediary/insurer at a time.

Remuneration

PoSPs are generally paid commission or incentive-based remuneration, as per contract terms with the appointing entity.

Compliance & Reporting

Insurers or intermediaries employing PoSPs must:

Maintain half-yearly returns to IRDAI.
Keep PoSP training, KYC, and product sales records.
Ensure that the PoSP adheres to the code of conduct and product restrictions.

Difference between ISP vs PoSP

Parameter	ISP (Insurance Sales Person)	PoSP (Point of Sales Person)
Regulatory Basis	IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015	IRDAI PoSP Guidelines, 2017 + Broker/Agent Regulations
Associated Entity	Insurance Marketing Firm (IMF)	Broker / Corporate Agent / Insurer
Employment Nature	Employee or appointed representative of IMF	Contractual associate of insurer/intermediary
Training Hours	50 (freshers) / 25 (experienced)	15 hours per product line
Certification	Conducted by IRDAI-recognized training institution via IMF	Conducted by insurer/intermediary through IRDAI-approved module
Remuneration Type	Fixed monthly salary (minimum Rs.5,000)	Commission or incentive-based
Product Scope	Life, general, and health products of tied-up insurers	Simple retail insurance products only
Tie-up Limit	One life, one general/health, one standalone health insurer	One intermediary or insurer at a time
Reporting Authority	IMF to IRDAI	Insurer/intermediary to IRDAI
Model Type	Institutional, compliance-heavy, long-term	Retail, flexible, quick-deployment
Objective	Enhance professional, advisory-driven insurance sales	Expand retail outreach for simple products

Why Cannot Appoint a PoSPs under the IMF model ?

Under the current IRDAI regulatory structure, the Insurance Marketing Firm (IMF) company and Point of Sales Person (PoSP) models operate under two distinct sets of rules designed for different segments of insurance distribution.

The IMF channel is governed by the IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015, which authorize IMFs to appoint and manage Insurance Sales Persons (ISPs) for soliciting insurance business. These ISPs are trained, certified, and salaried representatives who work exclusively under the IMF’s supervision.

In contrast, the PoSP structure is established under separate IRDAI guidelines applicable to insurers, brokers, and corporate agents. PoSPs function as independent, contract-based representatives who are permitted to sell simple, pre-approved insurance products after completing limited training and certification.

Since the IMF Regulations, 2015, contain no provision authorizing an IMF to appoint PoSPs, any such engagement would be non-compliant with IRDAI norms. IMFs are therefore restricted to operating only through ISPs registered under their own license.

How Compliance Calendar LLP Helps You Achieve Smooth IMF and Insurance Broker Registration

At Compliance Calendar LLP, we simplify the tedious regulatory journey of obtaining IRDAI registration and whether you are setting up an Insurance Marketing Firm (IMF) or an Insurance Broker Company. Our expert team of Company Secretaries, Chartered Accountants, and IRDAI compliance professionals allows you that every step of your application is executed with precision and in full adherence to the latest IRDAI guidelines.

From entity structuring to choose LLP registration or Private Limited Company including capital verification to drafting the business plan, LOIs from insurers, Principal Officer training, fit & proper declarations, and documentation in Form A, we manage the process end-to-end. We also assist with infrastructure readiness, compliance checklists, including IRDAI Broker or IMF Exam & Training guide and coordination with IRDAI officials until the registration certificate is successfully granted.

We at Compliance Calendar LLP, our experience with multiple clients across India allows us to anticipate common challenges whether it’s drafting the Letter of Intent (LOI) for insurers in case of IMF applications or meeting the net-worth, deposit, and personnel criteria under the IRDAI (Insurance Brokers) Regulations, 2018. We handle every procedural requirement so that you can focus on building your insurance distribution business confidently.

With Compliance Calendar LLP, your company registration process becomes seamless, transparent, and fully compliant with IRDAI’s expectations. From advisory to post-licensing compliance with MCA and IRDAI, We here act as your trusted partner in turning your insurance distribution vision into reality.