The Insurance Regulatory and Development Authority of India (IRDAI), in its response to public comments on the Exposure Draft of the 2026 Amendment Regulations, confirmed implementation of Ind AS-based financial reporting for insurers from 1 April 2026, with a one-year forbearance for entities facing difficulties. A two-year parallel reporting requirement under both Ind AS and existing IGAAP framework was retained. The Authority clarified that retrospective annual cohort requirements would not be adopted, though compliance with Ind AS 117 remains mandatory. Distribution of surplus will continue under the Insurance Act, 1938, with additional disclosure formats introduced. Guidance on risk-free rates, fund segregation, and regulatory aspects will be issued separately. Solvency norms under existing provisions will continue until the Risk Based Capital framework is implemented. Independent validation of Ind AS processes will be required initially, and a Joint Expert Group will be formed to support implementation. Overall, stakeholder inputs were considered, with modifications incorporated in the final regulations.
Insurance Regulatory and Development Authority of India
30.03.2026
General statement of response to the public comments on Exposure draft of Insurance Regulatory and Development Authority of India (Actuarial, Finance and Investment Functions of Insurers) (Amendment) Regulations, 2026
Public comments have been received from various stakeholders, including insurers, individuals and professional firms. Provided below is the gist of public comments along with the response of Insurance Regulatory and Development Authority of India (IRDAI).
| S. No. | Public Comments | IRDAI Response |
| 1. | Implementation Timelines
Some stakeholders support implementation from 1 April 2026, many have either suggested extension to 1 April 2027 or suggested phased implementation. Key challenges highlighted include legacy systems, lack of historical data and complexities in large-scale system integration. |
Mandatory adoption of Ind AS for all insurers with effect from 1 April 2026.
For insurers who are unable to prepare and present financial statements in compliance with Indian Accounting Standards, forbearance may be granted for one year subject to requirements specified in the regulations. Also, during the period of forbearance, the insurer shall also prepare and submit to the Authority, financial information in accordance with Ind AS on a quarterly basis. |
| 2. | Parallel Submission: Broadly stakeholders have supported
parallel submission during Many stakeholders suggested minimum two years’ parallel submission with current applicable accounting framework / IGAAP as statutory reporting. Key areas requiring clarity include duration and frequency of reporting (quarterly/annual), scope of IGAAP submissions (full vs abridged), audit vs limited review |
Parallel reporting shall be required for a period of two years or such period as may be specified. This will include preparation of Financial Statements in accordance with Ind AS and Financial Information in accordance with the
current applicable accounting |
| 3. | Segregation of Policyholder & Shareholder Funds: Broadly stakeholders are in alignment with the proposed approach. However,
some have suggested guidance on the identification and presentation of policyholder and shareholder fund segregation under Ind AS |
Further, any other requirements related to parallel submissions will be specified in the due course.
Maintenance of separate accounts for Policyholder and Shareholder funds shall continue as mandated under the Insurance Act, 1938. Further clarifications, if any, on fund segregation will be specified framework/ IGAAP. |
| 4. | Annual Cohort: Many
stakeholders have raised concerns on the proposed retrospective annual cohort requirement (10/15/20 years), referring to transition relief provided under Few stakeholders have also suggested exemption of annual cohort requirement under |
In view of the public comments
received, the proposal of retrospective annual cohort However, on transition, Insurers shall comply with the annual cohort requirement under Ind AS 117, |
| 5. | Surplus: Stakeholders are broadly aligned with actuarial surplus as the basis for distribution of surplus.
Clarity is sought on the presentation of non-distributable retained earnings, basis for and inclusion of a standard reconciliation format (Actuarial |
Section 49 (Restriction on dividends and bonuses) of the Insurance Act, 1938 (as amended by the Sabka Bima
Sabki Raksha (Amendment of Insurance Laws) Act, 2025) shall A separate line item for non- distributable retained earnings has been incorporated in the financial |
| 6. | Risk Free Rate (RFR): Broadly Stakeholders have supported alignment of risk free rate with the proposed Risk Based Capital framework while seeking interim guidance until the framework is finalised.
Clarification is also sought on whether discounting is restricted to the risk-free rate and whether the application of illiquidity premium and the Top-Down approach is allowed. |
The reference for determination of the
risk-free rate for discounting of Further, it is clarified that illiquidity |
| 7. | Audit: Stakeholders have highlighted the need for clarity on the independent validation framework, particularly the scope vis-à-vis statutory audit and publication of an empanelled auditor list. Further, there is suggestion for continuation of peer review/independent actuary review as in proforma submissions. | Independent validation of process
adopted in implementation of Ind AS shall be obtained by the Insurers during the first year or for such period as may be specified. The scope and manner of such validation to be provided in consultation with Joint |
| 8. | Solvency Framework:
Stakeholders broadly supported continuation of current applicable framework for valuation of assets and liabilities for solvency purposes until the proposed Risk Based Capital (RBC) framework is implemented. Other suggestions include implementing RBC prior to Ind AS, aligning solvency requirements with proposed RBC framework. |
For Solvency purpose, Sections 64V and 64VA of Insurance Act, 1938 shall continue to apply for insurers.
Further, it is expected that implementation of Ind AS will provide a sound foundation for subsequent calibration and implementation of |
| 9. | Other Regulatory Requirements: Stakeholders have sought clarity
on various regulatory aspects, including the applicability of Schedule I (Actuarial Functions) of IRDAI (Actuarial, Finance and Investment functions of Insurers) Regulation, 2024 and relevant Master Circulars, Regulation/ Circular related to Investment function, expenses of management, submission of |
Clarification on the mentioned regulatory aspects will be provided separately.
Further, Section 13 (Actuary Report) of the Insurance Act, 1938 (as amended by the Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025) shall be applicable to all Insurers. |
| 10. | Guidance: Stakeholders have highlighted the need for implementation support, including issuance of FAQs, guidance notes, and a dedicated helpdesk during the transition period. | A Joint Expert Group on Ind AS is proposed to be constituted with representation from the IRDAI, National Financial Reporting Authority (NFRA), Securities and Exchange Board of India (SEBI), Institute of Chartered Accountants of India (ICAI), and Institute of Actuaries of India (IAI) for the purpose of examining and addressing issues arising in the course of implementation of Indian Accounting Standards by insurers. |
| 11. | Taxation: Stakeholders have highlighted the need for clarity on taxation under Ind AS, with many recommending continuation of IGAAP / Form I basis for tax computation. | For tax purpose, applicable tax laws shall continue to apply. |
| 12. | Other clarifications / issues including Ind AS Financial Statement formats and Key performance parameters of insurers have been sought by some stakeholders. |
Clarifications, if any, on these issues will be provided separately. |
The above comments/ suggestions received within the prescribed timeline (3rd March, 2026 – 24th March, 2026) were considered and placed before the Competent Authority. Necessary modifications / changes have been carried out on the Draft Insurance Regulatory and Development Authority of India (Actuarial, Finance and Investment Functions of Insurers) (Amendment) Regulations, 2026.
