The Insurance Regulatory and Development Authority of India examined a licence renewal application of an insurance surveyor after identifying irregularities in survey volumes, complaints of outsourcing to unlicensed personnel, and inconsistencies in records. Upon scrutiny, it was found that multiple surveys were conducted and reports submitted during periods when the surveyor was abroad, indicating that unlicensed employees handled core functions. The surveyor admitted that employees assisted in surveys and, in some cases, completed tasks including report submissions. The Authority concluded that such delegation violated mandatory duties under the regulatory framework, which requires licensed professionals to personally conduct inspections and assessments. Additionally, contradictory explanations and implausible travel claims raised concerns about authenticity of records. The Authority held that outsourcing core survey functions and misrepresenting records constituted serious violations of professional duties and ethical standards prescribed under applicable regulations.
Further, the Authority found major discrepancies in survey registers and statutory filings, including conflicting data across multiple submissions and incorrect reporting in Form-12 returns. Evidence from insurers showed incomplete disclosures, incorrect attribution of surveys, and missing records, undermining the credibility of submissions. The surveyor also failed to maintain proper records and backups, violating mandatory record-keeping obligations. Significant delays in submission of survey reports were noted, with thousands exceeding prescribed timelines. The surveyor admitted delegating re-inspection work to unlicensed staff, citing industry practice and cost constraints, which was rejected as an invalid justification. Considering the cumulative violations—outsourcing of regulated functions, false reporting, record inconsistencies, and non-compliance—the Authority held that continuation of the licence was prejudicial to policyholder interests. Accordingly, the licence was cancelled with immediate effect, renewal application rejected, and liberty granted to apply afresh after one year.
Insurance Regulatory and Development Authority
Ref. No. IRDAI/INT/ORD/MISC/60/4/2026
Final Order in the matter of Shri Deependra Kumar Pandey, Insurance Surveyor and Loss Assessor (SLA) (License No. IRDA/IND/SLA-72887)
1. Background
1.1. The Insurance Regulatory and Development Authority of India (“The Authority”) is in receipt of a surveyor license renewal application no. 500054555 submitted on 17.08.2025 by Mr. Deependra Kumar Pandey for the renewal of his surveyor and loss assessor licence bearing no. IRDA/IND/SLA-72887. Mr. Deependra Kumar Pandey is currently acting as a director of DISB Insurance Surveyor and Loss Assessors Pvt. Ltd. (DISB). Upon preliminary scrutiny, his Licence was flagged for disproportionately high volume of surveys conducted in last three financial years. Consequently, the Authority sought clarifications from Mr. Deependra Kumar Pandey multiple times with a specific direction to produce his survey registers for last three financial years. Multiple irregularities observed in these survey registers and subsequent submissions raised concerns on regulatory adherence.
1.2. The Authority is in receipt of written complaints alleging engagement of unlicensed personnel for surveys by DISB and the authenticity of the returns filed under Form 12, along with documentary evidences. The complaints called for a thorough scrutiny of the renewal application and the records submitted along with it, as well as the documentary evidence submitted by the complainants. Subsequently, clarifications/remarks were sought from the surveyor who submitted his response through the BAP portal and various subsequent emails.
2. Show Cause Notice, Reply and Hearing
2.1. Upon examination of the submissions made by the surveyor, the Authority issued the SCN (Show-cause Notice) on 06.02.2026, to which the surveyor submitted his documented response vide letter dated 11.02.2026. While replying to the SCN, the surveyor also sought a personal hearing in the matter. The hearing was granted by the competent Authority and was held on 18.03.2026. The hearing was chaired by Member (Life) and Member (Non-Life).
On behalf of the Authority, Shri Sudipta Bhattacharya, Chief General Manager – Intermediaries (SLA & IR); Smt. Shiksha Shaha, General Manager – Intermediaries (SLA & IR); Shri Kurapaty Sridhar Rao – Deputy General Manager – Intermediaries (SLA & IR); Shri Chandan Singh, Manager – Intermediaries (SLA & IR); Smt. Priya Yadav – Assistant Manager – Intermediaries (SLA & IR) and Shri Rasure Rajneesh Ravindra – Assistant Manager – Intermediaries (SLA & IR) were present during the said hearing.
3. Based on
The submissions made by the surveyor in his written reply to the Show Cause Notice (SCN) dated 11.02.2026, as well as the submissions made during the course of the personal hearing held on 18.03.2026 at 02:30 PM, chaired by Member (Life) and Member (Non-Life), have been duly considered. The findings and decisions on the charges are set out hereunder.
4. Charges
4.1. Charges 1 and 3: Outsourcing survey jobs to unlicensed personnel and submitting false registers.
4.1.1. Charge 1: Outsourcing survey jobs to unlicensed personnel.
– Violation of Regulations 13(1)(d), 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.1.1.1. Observations:
On perusal of the copy of the passport submitted by the surveyor, it was observed that the surveyor had travelled out of India on 03.04.2024 and returned on 10.04.2024. The survey register submitted by him vide mail dated 01.12.2025 indicates that he had conducted 45 surveys during this period of absence from India.
4.1.1.2. Submissions of the surveyor:
The surveyor had left India on 03.04.2024 at 11:30 PM and returned to India on the night of 10.04.2024. Hence, he personally attended and completed eight surveys on 03.04.2024.
The work for rest of the six days on 37 surveys was carried out by his employees who provided limited logistical assistance such as collection of photographs and follow-up documentation under his strict directions. He remained available on official systems as well as on telephone throughout this period for all decisions, guidance, and oversight related to the work. He claimed that he personally visited the said locations after returning to India and reviewed findings, verified the facts, finalised the survey reports. No report was finalised without his personal verification and professional satisfaction, and all surveys were handled under his licence in accordance with prevailing professional practice, without any intention to misrepresent facts.
In his personal hearing, surveyor stated that these surveys involved small value claims and acknowledged the fact that some of these surveys were conducted and their survey reports were submitted to insurers by his employees before his arrival back in India.
4.1.2. Charge 3: Outsourcing survey jobs to unlicensed personnel and submitting false survey registers.
– Violation of Regulations 13(1)(d), 16(1), 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.1.2.1. Observations:
Authority is in receipt of the copies of the survey bills of two surveys in Bihar, both signed by Mr. Deependra Kumar Pandey (Claim No. 301402201122110010001 and MOT1126849). The former bill is dated before the period for which survey registers were sought and the latter has been attributed to Mr. Pradeep Kumar Singh (former director of DISB) in the survey registers submitted by the surveyor.
Geographically the surveyor would have had to travel over larger distances within a day to conduct the surveys such as 815KM on 01.07.2022, 865KM on 11.04.2023 and 1108KM on 31.10.2023. Surveyor in his submission dated 21.11.2025 attributed some of these surveys to his former partner Mr. Pradeep Kumar Singh.
These surveys could not have been completed by one person on the same day given their geographical location spread across large distances, this along with the complaints referred under Para 1.2, infer that these surveys were outsourced to unlicensed employees.
While trying to justify the possibility of conducting certain surveys, surveyor submitted that those surveys were “only photo snapped by assistant under guidance”, categorically admitting outsourcing his primary duties and responsibilities to un-licensed employees.
4.1.2.2. Submissions of the surveyor:
Surveyor claimed that all the surveys conducted in the State of Bihar were attended exclusively by Mr. Pradeep Kumar Singh during his tenure at DISB (October 2020 to September 2022).
Surveyor submitted that while the two sample fee bills of the surveys conducted in Bihar submitted to the Authority had his signature, the actual survey assessment reports were signed by Mr. Pradeep Kumar Singh.
In his hearing, surveyor firmly stated that the survey records submitted by the insurers pertaining to his firm were incorrect. He also stated that his earlier submission on 21.11.2025 that “The survey at Varanasi was conducted by Mr. Pradeep Kumar Singh” (Date of Survey: 11.04.2023) was an error on his behalf.
With reference to the phrase “only photo snapped by assistant under guidance”, surveyor submitted that the same pertains only to photographic documentation collected by support staff under explicit instructions, without any exercise of professional judgment. He also stated that all site inspections, assessments and professional judgments were personally conducted by him in accordance with applicable regulatory norms. Supporting staff assisted only in ancillary and non-technical activities.
4.1.3. Findings towards Charge 1 and Charge 3:
It has been clearly observed from the survey register submitted by the surveyor that some of the surveys were conducted and their final report was submitted to the insurers while surveyor himself was outside India. The same was confirmed by him during the personal hearing. This established that the entire survey procedure was handled by his unlicensed employees including submission of the final report that must be countersigned by the director of the firm as per Regulation 16(18) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015. This also contradicts surveyor’s claim of personally visiting the sites of the survey jobs in question. The fact that these jobs were conducted by his un-licensed employees violates Regulation 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 and goes against the Duties and Responsibilities of a Surveyor and Loss Assessor enumerated under Regulation 13 of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
While surveyor maintains that he conducted on-site inspection of all the other surveys, he also states that his employees only photo snapped some of these surveys when asked to justify their plausibility. His statements are contradictory to his own claim of conducting on-site inspections of these surveys, which is the primary duty of a licensed Surveyor and Loss Assessor as per Regulation 13(1)(d) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015. This conduct is in violation of the Code of Conduct as enumerated under Regulation 16(1) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 which requires every Surveyor and Loss Assessor to behave ethically and with integrity in the professional pursuits and Regulation 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 which mandates that a director of a corporate firm shall ensure that interim and final survey assessment is carried out by a licensed Surveyor and Loss Assessor.
4.1.4. Decision:
As per Sec. 64UM of the Insurance Act, 1938, no person shall act as a Surveyor and Loss Assessor in relation to general insurance business unless he holds a valid licence issued by the Authority. Moreover, Regulation 16(19B) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandates that the Director of a firm must ensure that interim and final survey and loss assessment be carried out by a licensed surveyor and loss assessor. Conducting inspection and re-inspection of the property in question suffering a loss is a responsibility of a licensed Surveyor and Loss Assessor.
The surveyor in his submissions has admitted that surveys were conducted and their final reports were submitted to the insurers by his un-licensed employees in his absence and certain functions were delegated to his un-licensed employees occasionally. Moreover, certain primary responsibilities were also outsourced to his un-licensed employees which is evident in his own submissions. This constitutes a violation of the “Duties and Responsibilities of Surveyor and Loss Assessor” prescribed under Regulation 13 of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 and “Code of Conduct” prescribed under Regulation 16 of the regulatory framework.
The Authority is of the opinion that the continuation of the license of the surveyor is prejudicial to the interests of the policyholders.
4.2. Charges 2 and 4: Failure to maintain survey records, submitting false survey register and filing false returns with the Authority.
4.2.1. Charge 2: Failure to maintain survey register and filing false returns with the Authority.
– Violation of Reg. 16(1), 16(9), 16(13) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.2.1.1. Observations:
Survey registers were sought owing to the unusually high number of surveys conducted by the surveyor. Surveyor initially requested an exemption from submitting the survey register claiming that his records were lost in a system crash. He later went on to submit four conflicting versions of the same when insisted by the Authority.
The final version of survey register submitted by the surveyor, revealed that he conducted 1230, 1988, 1622 surveys in financial years 2022-23, 2023-24, 2024-25 respectively as against 2496, 2101, 2316 surveys reported by him in respective financial years under Form-12 returns. This called into question the authenticity of the survey register submitted by him and his returns filed under Form-12 with the Authority, the annual submission of Form-12 with the Authority is mandated in the regulations
As per his latest submissions, 22 Final reports of the surveys in Bihar and 50 other surveys reportedly done by Mr. Pradeep Kumar Singh have been submitted to the insurer after the alleged date of exit of Mr. Pradeep Kumar Singh from DISB. This indicates the possibility of involvement of the surveyor in final report submission for these surveys.
4.2.1.2. Submissions of the surveyor:
Surveyor reaffirmed in his documented response that the disparity between Form-12 returns and survey register was solely due to the aforementioned data loss and submitted that that there has been no wilful manipulation, suppression, falsification, or re-attribution of Survey Registers at any stage. All submissions made to the Authority were in good faith, based on the data available at the relevant point of time, and strictly in response to successive directions issued by the Authority and that there has been no change whatsoever in the total number of surveys conducted/reported in DISB. The differences between versions relate solely to addition of mandatory regulatory columns, improved segregation of data, and reconciliation of legacy system-generated records.
4.2.2. Charge 4: Submitting false survey registers to the Authority.
– Violation of Reg. 16(1), 16(9), 16(13) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
Four conflicting versions of the register were submitted by the surveyor on 22.09.2025, 26.09.2025, 14.11.2025, 01.12.2025.
In light of the conflicting submissions of survey registers by the surveyor, Authority sought information from Insurers exclusively regarding the surveys conducted by DISB in the state of Bihar. It was observed that the surveyor had failed to disclose full extent of these survey jobs conducted by him in his submissions. Insurer also flagged additional survey activity in West Bengal and Jharkhand.
4.2.2.1. Submissions of the surveyor:
Surveyor stated that all of the Bihar region surveys have been solely conducted by Mr. Pradeep Kumar Singh. Surveyor completely denied having any active operations in West Bengal and Jharkhand.
Surveyor in the hearing stated that the survey records submitted by the insurers pertaining to his firm were incorrect.
4.2.2.2. Findings towards charges 2 and 4:
Post personal hearing, the Authority sought sample reports of the surveys pertaining to DISB from the concerned insurers. As per the copies of 24 sample survey reports submitted by SBI GIC to the Authority, all were found to be countersigned by Mr. Deependra, details of five of these survey jobs were found to be absent from the survey register provided by the surveyor. Rest of the surveys have been miss-attributed to Mr. Pradeep Kumar Singh in the records submitted by the surveyor. All of these surveys have been conducted in the state of Bihar.
As per the 30 sample reports submitted by Go Digit GIC, eight were not conducted by DISB as opposed to earlier submission of Go Digit GIC. When inquired about the details of one of these surveys, surveyor had refused conducting the same during his personal hearing. However, in rest of the 22 surveys, surveyor has either reported incorrect survey details such as location of the survey or has attributed them to his partners.
Three of these reports have been countersigned by Mr. Deependra Kumar Pandey himself. In the register submitted by the surveyor, one of them has been attributed to Mr. Sharmajeet Singh, another director of DISB, another survey to Mr. Pradeep Kumar Singh and a wrong location for the third survey has been reported and it has been attributed to the surveyor himself.
Stamp of DISB was noticed on rest of the 19 reports, details of a survey pertaining to one of these reports is absent from the records submitted by the surveyor, another survey has been attributed to Mr. Sharmajeet Singh and a wrong location has been reported for the same. 16 of the other surveys have been attributed to Mr. Pradeep Kumar Singh in the records shared by the surveyor.
4.2.3. Decision:
Submitting incomplete, incorrect records to the Authority violates Regulation 16(1) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 that requires every Surveyor and Loss Assessor to behave ethically and with integrity in the professional pursuits.
Every Surveyor and Loss Assessor must submit annual statement in Form-12 as per the Regulation 20(2) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015. While the surveyor submitted his Form-12 returns, he provided incorrect details under the same as evident from his own submissions and the information provided by the insurers.
While the surveyor had earlier claimed data loss due to system failure, he has provided a survey register full of inaccuracies later. Even though he had access to necessary data that would have allowed him to reconcile the register, he only did so when insisted upon by the Authority. He also failed to maintain a backup of the necessary records.
Regulation 16(9) and 16(13) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandate that a Surveyor and Loss Assessor must maintain a proper record of the work done by the surveyor and maintain a register of survey work. Surveyor failed to comply with both of these regulations.
The Authority is of the view that the disregard of the regulations, incorrect submissions observed here are of serious and substantive nature and warrant a regulatory action.
4.3. Charge 5: TAT Violations.
– Violation of Regulation 13(2) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.3.1. Observations:
In perusal of the complaint dated 09.10.2025 wherein it was alleged that the Surveyor had bribed IFFCO TOKIO GIC employees in return for allocation of more survey jobs, clarification was sought from IFFCO TOKIO GIC. The insurer confirmed cessation of survey allocations to the firm because of consistent delays in handling cases and other complaints of internal conflicts in DISB amounting to violations of Turn-Around-Time (TAT) vide their mail dated 18.12.2025.
4.3.2. Submissions of the Surveyor:
Surveyor attributed special circumstances, complexity, delayed repairs, police custody and external dependencies etc. as factors for TAT violations and claimed that “both the insurer and the insured were fully informed and aware of the delays arising due to the specified circumstances”.
4.3.3. Findings:
Consolidated Survey registers consisting details of the surveys conducted by DISB Insurance Surveyor and Loss Assessors submitted by the surveyor revealed that survey reports were submitted beyond 30-days timeline in 3497 instances out of 13,819 survey jobs. In 206 instances, reports were submitted after 180 days.
4.3.4. Decision:
Regulation 13(2) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandates that survey report should not be submitted later than 30 days of the assignment of survey job without prior consent of the insurer and in no case shall submit it after six months. Authentic concerns were raised by the surveyor when these issued were pointed out. Certain factors related with the preparation of final report are not entirely in control of the surveyor.
The submissions of the Surveyor, in this regard have been noted by the Authority.
4.4. Charge 6: Outsourcing re-inspection to unlicensed personnel.
– Violation of Regulation 13(1)(d) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015.
4.4.1. Observations:
In his response dated 12.12.2025, surveyor mentioned “under repair and re-inspection” in the job profile of seven of his employees.
Surveyor categorically admitted violating regulatory norms by using un-licensed staff on his behalf to meet insurers’ demand and timelines. Surveyor also stated that same was done because insurers do not pay separate fees for re-inspection.
4.4.2. Submission of the surveyor:
Surveyor in his hearing explained it as “General market practice” and claimed that it was done in low value claims. Surveyor also stated that his employees were engaged only for limited assistance.
4.4.3. Findings:
Surveyor in his documented and oral response has admitted that re-inspection activities were carried out by his employees.
4.4.4. Decision:
Regulation 13(1)(d) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 mandates that it is a duty of Surveyor and Loss Assessor to conduct inspection and re-inspection of property in question suffering a loss. The Surveyor has acknowledged delegating re-inspection duties to unlicensed personnel. His submission that such delegation was necessitated by the absence of supplementary remuneration from insurers is untenable and fails to constitute a valid justification for the regulatory breach.
5. Final Decision
Documentary evidence on record conclusively establishes a gross failure by the surveyor to comply with the regulatory framework across the specified charges. Given the severity and material nature of the infractions observed under Charges 1, 2, 3, 4, and 6, it is the considered view of the Authority that the Surveyor has acted in wilful contravention of the Insurance Act, 1938, and its attendant Regulations, rendering him liable for the disqualifications set forth under Section 42D of the Act. Accordingly, pursuant to Regulation 24 of the IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015, the license granted to the Surveyor is hereby cancelled.
The Surveyor and Loss Assessor license of Shri Deependra Kumar Pandey (License No. IRDA/IND/SLA-72887) is cancelled with immediate effect as per Regulation 24(1) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015. The renewal application filed vide unique reference number 500054555 also stands rejected.
The Surveyor in accordance with the Regulation 24(3) of IRDAI (Insurance Surveyors and Loss Assessors) Regulations, 2015 may submit an application for issuance of a surveyor license, after expiry of one year from the date of cancellation. Such application shall be treated as an application for grant of fresh licence.
If the surveyor is aggrieved by any portion of this order, he may prefer an appeal before the Securities Appellate Tribunal within a period of 45 days from the date of receipt of this Order as per Section 110 of the Insurance Act, 1938.
Notwithstanding anything in this order, the Authority reserves the right to initiate regulatory proceedings against DISB Insurance Surveyor and Loss Assessor.
Place: Hyderabad
Date: 30.04.2026
SD-
(Deepak Sood)
Member (Non-Life)
SD-
(Swaminathan Iyer)
Member (Life)
