Policybazaar Penalized Rs. 4 Crore by IRDAI for Regulatory Breaches

Insurance Regulatory and Development Authority of India (IRDAI) has issued an order imposing a total penalty of Rs. 4 crore on Policybazaar Insurance Web Aggregator Pvt Ltd (now M/s Policybazaar Insurance Brokers Pvt Ltd.) for multiple violations of insurance regulations. The regulatory body found the company in breach of several disclosure requirements, product display norms, outsourcing agreements, and premium remittance rules.

Disclosure and Principal Officer Violations Lead to Initial Penalty

The IRDAI’s investigation found Policybazaar in violation of disclosure requirements regarding changes in directorships. The company argued that disclosure under specific clauses was only necessary upon the Authority’s request and that directorships in non-insurance companies were not material. However, the IRDAI rejected these claims, asserting that regulations mandate automatic disclosure of all material changes, including director changes in both insurance and non-insurance entities, within 30 days to prevent conflicts of interest and ensure effective time management of Key Managerial Personnel (KMPs).

A significant breach involved Mr. Manoj Sharma, who served as CEO and Principal Officer (PO) for over four years while simultaneously holding directorships in other companies. This directly contravened regulations requiring the PO to exclusively serve the Insurance Web Aggregator (IWA) without outside directorships or employment. Policybazaar failed to obtain prior IRDAI approval for these directorships and did not disclose them, leading to perceived conflicts of interest and operational risks. For these violations, the Authority imposed a penalty of Rs. One Crore under Section 102 of the Insurance Act, 1938.

Domain Ownership and Financial Sharing Concerns Addressed

Initial concerns were raised regarding Policybazaar’s compliance with regulations on ownership and registration of domain names/websites. The domain “policybazaar.com” was found to be owned by the holding company, not the IWA itself, with license fees paid to the holding company. Additionally, the IWA was sharing infrastructure and other expenses with its holding company without formal agreements.

Policybazaar clarified that while the brand name is held by the parent entity, the designated website domain adheres to regulations. They submitted a KPMG report recommending a 3% license fee to the holding company (down from 5%), along with board approvals for expenses and audited financial disclosures. The company also provided an undertaking to comply with arm’s length principles and relevant laws. Consequently, the IRDAI accepted Policybazaar’s submissions on this charge, and it was not pressed further.

Client Diversion Allegations Dismissed

Another charge involved the alleged diversion of clientele from Paisabazaar.com (operated by a group company) to Policybazaar for life and health insurance needs without prior regulatory approval. Policybazaar defended this practice, stating that all sales occurred solely on its IWA website and that this activity constituted digital insurance marketing, not solicitation, which is common industry practice. The company also asserted that no customer personal data was transferred between the entities and no payments were exchanged for this referral. The Authority accepted these explanations, and this charge was also not pursued.

Misleading Product Display and Ranking Draws Penalty

The IRDAI identified significant violations concerning the misleading display and ranking of insurance products on Policybazaar’s website. Inspection findings revealed that the website displayed only five ULIP products as “Top products” despite agreements with numerous insurers offering ULIPs. The site also utilized terms like “Top,” “Best Life Insurance Plans in India 2020,” and “Top plans-health insurance” to rank or select specific insurers and products. Furthermore, endorsements and promotions favoring certain insurers were displayed, potentially limiting consumer choice and misleading customers.

Policybazaar claimed no intentional ranking or endorsement, stating that the problematic page was removed post-inspection and that terms like “Top” and “Best” were used inadvertently in generic articles. They committed to greater caution. However, the Authority ruled that Policybazaar is prohibited from ranking, endorsing, or promoting specific insurers/products unless based on verified third-party data that is transparently disclosed. The IRDAI emphasized that promotional terms without transparency mislead customers and limit informed choices, and that displaying only select insurers’ products as “Top” constitutes biased advertising. The company’s reliance on search engine rankings as justification was deemed unacceptable, with the Authority noting Policybazaar’s market leadership necessitates a higher responsibility for impartial information. For these violations, a penalty of Rs. One Crore was imposed under Section 102 of the Insurance Act, 1938.

Outsourcing Agreement Irregularities Lead to Fine

Policybazaar was found in violation of regulations pertaining to outsourcing agreements and service charges with insurers. Inspection revealed that many agreements lacked clarity on exact services or charges, with some covering prohibited activities like pre-sales services or exclusive outsourcing. Payment structures were predominantly on a “per seat” basis, with inconsistent rates charged by insurers (Rs. 35,000 to Rs. 50,000 per seat). Large payouts from insurers for outsourcing activities were noted, amounting to Rs. 81.9 Cr (FY 2017-18), Rs. 151.84 Cr (FY 2018-19), and Rs. 255.96 Cr (FY 2019-20). Crucially, Policybazaar failed to provide service level data or telephonic recordings to confirm that outsourcing strictly related to policies sourced by the IWA.

Policybazaar argued that commissions and outsourcing fees were within IRDAI limits and reasonable, and that per-seat charging is standard for tele-calling. They also stated that these arrangements have since ceased. However, the Authority concluded that regulations require clear scope of services, defined charges, and reasonable fees directly linked to services rendered for policies sourced by the IWA. Charging on a per-seat basis without correlating to the number or nature of services was deemed questionable and lacking transparency. The absence of telephonic recordings and service data raised suspicions that fees were earned for policies not sourced by Policybazaar. The company failed to justify the large payouts or provide adequate explanations, leading to a penalty of Rs. One Crore under Section 102 of the Insurance Act, 1938.

Unmapped Policies and Call Recording Deficiencies Flagged

The IRDAI identified issues with Policybazaar’s maintenance of policy and Authorized Verifier (AV) details. A significant number of policies sold via “Telemarketing mode” (97,780 out of 4,32,366) were mapped as “unassisted” or “unmapped,” indicating a failure to tag individual policies to the AV who concluded the sale. Policybazaar also failed to provide solicitation-related documents, including call recordings, even for a single policy.

Policybazaar cited practical challenges with the tagging process and stated they have since strengthened their AV tagging system, fully implementing it by April 2019. However, the IRDAI found that Policybazaar failed to provide the requested data during the inspection, raising concerns about whether these policies were genuinely sourced within regulatory frameworks. The Authority expressed concern that the inability to provide data swiftly could hinder customer service and regulatory oversight. For these lapses, a penalty of Rs. One Crore was imposed under Section 102 of the Insurance Act, 1938, and Policybazaar was directed to ensure each online-solicited policy is tagged to its AV and to provide prompt access to such records to the Authority. Policybazaar was also cautioned and directed to carry out an audit of its call recording processes.

Delayed Premium Remittance and Commission Excesses Noted

Policybazaar was found to have collected insurance premiums on behalf of insurers without specific authorization and used its own payment gateway and Nodal Account for premium transmission without IRDAI approval. The company remitted significant amounts of premium through its Nodal Account, with delays exceeding the mandated 24-hour window (excluding holidays) for intermediaries, as per Section 64VB of the Insurance Act, 1938, and IRDAI circulars.

Policybazaar argued they collected premiums based on specific insurer authorization and that RBI circulars allow for a “T+3” settlement cycle for online remittances, and that the 24-hour rule does not account for digital payment challenges. They stated that for over 99% of policies, premium is remitted within 24 hours, and they are working to ensure full compliance. The Authority rejected the “T+3” argument, reaffirming the 24-hour remittance requirement for insurance intermediaries to protect policyholder interests and ensure timely coverage. The IRDAI noted that an intermediary has no right over premiums and that delayed remittance poses a systemic risk. For this violation, a penalty of Rs. One Crore was imposed, and Policybazaar was advised to ensure compliance with Section 64VB.

Separately, Policybazaar received insurance commission in excess of prescribed remuneration in eight sample cases, exceeding the 15 percent limit. Policybazaar stated that this was due to older regulations (17.5% for health insurance) and reconciliation delays. The Authority cautioned Policybazaar for this lapse and advised adherence to current guidelines.

Authorized Verifier Agency Licenses Highlight Due Diligence Gaps

The inspection revealed that several of Policybazaar’s Authorized Verifiers (AVs) held valid insurance agency licenses in their individual capacity, which is a violation of regulations. Policybazaar acknowledged that this was from 2015-16 and that they now use IRDAI’s “PAN Look Up facility” and ENVOY portal for verification. They stated they have cautioned employees and enhanced their governance framework. The IRDAI concluded that Policybazaar failed to conduct proper due diligence, relying on employees for self-disclosure, indicating deficiencies in internal controls. Policybazaar was cautioned for this lapse and advised to comply with extant guidelines.

******

Insurance Regulatory and Development Authority of India

Ref. IRDAI/E&C/ORD/MISC/88/07/2025

Order in the matter of M/s Policybazaar Insurance Web Aggregator Pvt Ltd.
(Now known as M/s Policybazaar Insurance Brokers Pvt Ltd.)

1. Based on the

1.1. Show Cause Notice (“SCN”) reference No. IRDA / ENF / 2023 / 700 / SCN / LR / 059 dated 7th October, 2024 issued to M/s Policybazaar Insurance Web Aggregator Pvt. Ltd. ( “IWA” or “the Company”) in connection with the remote inspection conducted by the Authority.

1.2. Submissions made by the IWA vide email dated 12th November, 2024 in response to the aforesaid SCN.

1.3. Submissions made by the IWA during the personal hearing held on 11th February, 2025 at 02.30 PM, by the panel of Two Whole Time Members of the Authority – Shri Satyajit Tripathy (Member-Distribution) and Shri P K Arora (Member-Actuary).

1.4. Further submissions made by the IWA vide email dated 26^th February, 2025.

2. Background

2.1. The Authority had conducted the remote inspection of IWA from 1^st to 5th June 2020. The inspection report, inter alia, revealed certain violations of provisions of the Insurance Act, 1938 and Regulations and Guidelines issued thereunder.

2.2. A copy of the inspection report was forwarded to the IWA on 11^th September, 2020 seeking their response and the response was received vide email dated 9^th October, 2020.

2.3. On examining the submissions made by the IWA, Show Cause Notice (SCN) was issued on 7^th October 2024. The IWA replied to the SCN vide email dated 12^th November 2024.

2.4. As requested for by the IWA, personal hearing was granted to the IWA on 11^th February, 2025 by the Panel of Two Whole Time Members of the Authority- Satyajit Tripathy (Member-Distribution) and Shri P K Arora (Member-Actuary).

2.5. On behalf of the IWA, Shri Yashish Dahiya (Co-founder & Group CEO), Shri Sarbvir Singh (President & Joint Group CEO), Shri Tarun Mathur (Principal Officer and CEO), Shri Santosh Agarwal (Chief Business Officer – Life Insurance), Smt. Deepti Rustagi (Group Head- Legal & Compliance) and Shri Praman Preet Singh Gujral (Chief Compliance Officer) and on behalf of the Authority, Shri R K Sharma (Chief General Manager), Shri T.V. Rao (General Manager), Shri Sanjay Kumar Verma (General Manager), Shri Manoj Kumar Asiwal (Deputy General Manager), Shri Saket Gupta (Manager) and Shri Atul Gupta (Assistant Manager) attended the hearing.

2.6. The submissions made by the IWA in its email dated 09^th October 2020, submissions made after SCN vide email dated 12^th November 2024 and submissions made during the personal hearing on 11^th February, 2025 and those made vide email dated 26^th February, 2025 have been carefully considered by the Authority and are summarized below:

3. Charge-1 (Observation-1)

3.1. Violations of –

a) Clauses 1(i), 2 and 3 (ii) of Form N under Schedule III read with Regulation 23 of IRDAI (Insurance Web Aggregators) Regulations, 2017;

b) Regulation 2(l) of IRDAI (Insurance Web Aggregators) Regulations, 2017;

c) Clause 5 of the Undertaking of Form G under Schedule II read with Regulation 13(b) of IRDAI (Insurance Web Aggregators) Regulations, 2017.

3.2. Inspection Observation-1

3.2.1. Key Managerial Personnel (KMPs) and employees of the web aggregator are having directorships in other companies. The principal officer (PO) of the IWA holds directorship in the following companies, in addition to having directorship in IWA:

• Paisabazaar Marketing and Consulting Private Limited;
• I call Support Services Private Limited;
• PB Marketing and Consulting Private Limited (formerly known as Policybazaar Insurance Broking Private Limited);
• Accurex Marketing and Consulting Private Limited;
• Docprime Technologies Private Limited (formerly known as Panacea Techno Services Private Limited).

3.2.2. In addition, it is also observed that President, Head of Operations, Director General Insurance Business and BU Head were holding the position of the directorship in other entities. Following KMPs are having directorships in other companies.

Name of the Employee	Date of Joining	Position Held	Details of Directorship in other entities, if any
Mr. Sarbvir Singh	25th November, 2019	President	Blue Jay Finlease Limited
			Class 21A Technologies Private Limited
			Inclov Technologies Private Limited
Mr. Sharat Dhall	18th Nov,2019	Head of Operations	TSI Voyages Private Limited
Mr. Tarun Mathur*	1st October, 2015	Director, General Insurance Business (Motor, Health, Travel)	Insol Marketing and Consulting Private Limited
			FE Global Technology Services Private Limited

3.3. Summary of IWA’s Submissions:

3.3.1. IWA submitted that there is no explicit obligation cast upon a web aggregator under the IRDAI IWA Regulations to disclose information about the directorship details of its KMPs and employees in other companies, on an on-going basis to the Authority.

3.3.2. Any change in directorship position of the KMPs and employees in other companies ‘that are not Insurance related’ should not be considered as a material change in the composition of a web aggregator.

3.3.3. During personal hearing IWA submitted that, at the time of applying license for Insurance Web Aggregator, Principal Officer (PO) was not holding directorship in any other company. However, the same was disclosed at the time of renewal of the license. The then Principal officer continued to hold the position for the last five years and a new person has been appointed in the FY 2024-25.

3.3.4. IWA apologized for not taking the prior approval of the Authority. Post Personal Hearing, the IWA submitted that current Principal Officer and Key Managerial Personnel (KMPs) are not holding directorship in any other company.

3.3.5. During the personal hearing, IWA was advised to submit (a) the date of resignation of previous Principal Officer; (b) date on which other KMPs resigned from the positon of director in other companies, (c) an undertaking to the effect that Principal Officer and Key Managerial Personnel (KMPs) are not holding directorship in any other company/ies.

3.3.6. The IWA submitted the date of resignation of previous PO. However, IWA failed to submit the date of resignation of Mr. Tarun Mathur, (present Principal Officer) from M/s Insol Marketing & Consulting Private Ltd and M/s FE Global Technology Services Private Limited on the grounds that the names of these entities have been struck off under the Companies Act.

3.3.7. Further, the IWA has submitted that one of the official holding the positon of President is not a part of the KMPs. As PB Fintech’s Joint Group CEO, his responsibilities include overseeing multiple PB group entities and his role is limited to that of a mentor and advisor providing strategic guidance, sound counsel and risk mitigation strategies to the group entities.

3.4. Decision on Charge- 1

3.4.1. IWA’s argument that clause 1(i) of Form N under Schedule III read with regulation 23 of IRDAI (Insurance Web Aggregators) Regulations, 2017, requires the disclosure to be made only on requisition by the Authority, is not tenable on a combined reading of the said clause with the ensuing provision i.e. Clause 2 and 3(ii) which read as follows:

2 “An Insurance Web Aggregator shall disclose to the Authority on his own any material change in the composition of the Insurance Web Aggregator within 30 days of such change”

3(ii) “An Insurance Web Aggregator shall take the prior approval of the

Authority for………. .change in Director / s or Designated Partner / s as the case may be”.

3.4.2. Further, IWA’s submission that any change in directorship position of the KMPs and employees in other companies ‘that are not Insurance related’ should not be considered as a material change is erroneous. The Regulations nowhere make a distinction between the directorship in insurance and non-insurance entities as the objective of the regulation is to mitigate and avoid conflict of interest, governing risk and the time management of the KMPs/PO. As the KMPs having Directorship in other companies is a material fact which needs to be disclosed by IWA on their own within 30 days of such change. However, IWA failed to do so. Further, clause 5 of the undertaking under Form G makes it abundantly clear that PO is exclusively appointed to carry out the functions of IWA and must not hold directorship / employment/assignment in other insurance related or any other entity.

3.4.3. Mr. Manoj Sharma resigned as CEO and Principal Officer (PO) only in August, 2024. He was PO for more than 4 years and holding positions in other companies contrary to the regulations leading to possible real or perceived conflict of interest. A PO with multiple responsibilities may fail to discharge these duties effectively, leading to operational and legal risks and for this reason precisely the norms with respect to the PO of an IWA have been stringent. The definition of “Principal Officer” itself under Regulation 2(l) makes it mandatory for PO and CEO to exclusively carry out the functions of IWA. IWA failed to take corrective action in due time in compliance with the regulations. IWA is in violation of Regulation 2(l) of IRDAI (Insurance Web Aggregators) Regulations, 2017 and Clause 5 of the undertaking under Form G under Schedule II read with Regulation 13(b) of IRDAI (Insurance Web Aggregators) Regulations, 2017 which state that Principal Officer is exclusively responsible for the activities and functions of IWA and must not hold directorship/employment/assignment in other insurance related or any other entity. However, Principal Officer of IWA was holding directorship in other companies in addition to having directorship in IWA. Moreover, IWA failed to take the prior approval of the Authority before appointment of the Principal Officer of IWA as director in other companies thus defeating the disclosure requirements by operating in an opaque manner.

3.4.4. In view of the above, in exercise of the powers vested under Section 102 of the Insurance Act 1938, the Authority hereby imposes a penalty of Rs. One Crore for the violation of Clauses 1(i), 2 and 3 (ii) of Form N under Schedule III read with regulation 23 of IRDAI (Insurance Web Aggregators) Regulations, 2017; Regulation 2(l) of IRDAI (Insurance Web Aggregators) Regulations, 2017 and Clause 5 of Form G under Schedule II read with regulation 13 of IRDAI (Insurance Web Aggregators) Regulations, 2017.

4. Charge-2 (Observations-2 & 15)

4.1. Violations of –

a) Clauses b (iii) (a) (1) and b(iii) (a) (2) of Form P under Schedule IV read with regulation 31 of the IRDAI (Insurance Web Aggregators) Regulations, 2017;

b) Clause 1(a) (iv) of Form X under Schedule IX read with regulation 33 of the IRDAI (Insurance Web Aggregators) Regulations, 2017;

c) Regulation 2(k) of IRDAI (Insurance Web Aggregators) Regulations, 2017.

4.2. Inspection Observation-2 and Observation-15

4.2.1. The IWA regulations require that the domain names of primary or secondary or product category specific websites are owned and registered in the name of IWA. However, it is noticed that the website of policybazaar.com is owned by its holding company. IWA has paid license fee @ 5% of the revenue to the holding company for usage of domain name. During FYs 2018-19 and 2019-20, a sum of Rs 15.51 Crore and Rs 25.79 Crores respectively has been paid to the holding company.

4.2.2. Further, on examination of the documents submitted by the IWA, it is concluded that the submissions of the IWA with regard to owning of domain name/website policybazaar.com are not found true.

4.2.3. On the examination of the financial statement for the FY 2018-19, it has been observed that IWA is sharing the Infrastructure and other cost with its Holding Company without having a valid agreement as under:

(Rs. Lakh)

S No.	Name of the Related party	Nature of Expense Charged	Amount
1	Etechaces Marketing and Consulting Pvt Ltd	Cost charges back by Holding Company for sharing of resources	452.77
2	Etechaces Marketing and Consulting Pvt Ltd	Amount reimbursed to Holding /Fellow Subsidiary Company against expenses	3.06
3	Etechaces Marketing and Consulting Pvt Ltd	Electricity expenses paid on behalf of Holding Company	92.21
4	Etechaces Marketing and Consulting Pvt Ltd	Security deposit paid on behalf of Holding Company	10.72

4.3. Summary of IWA’s Submissions:

4.3.1. IWA submitted that the brand name “Policybazaar” and “Policybazaar.com” and not the website “www.policybazaar.com” is owned by the holding company. Moreover, IRDAI IWA Regulations requires the designated Website, but not the “trademark”, along with the domain name to be owned by a web aggregator.

4.3.2. During personal hearing, IWA submitted that an independent report by KPMG recommended license fee @ 3% of the revenue to the holding company. The IWA has implemented the recommendation. IWA also confirmed that they still have agreement with holding company for similar activities.

4.3.3. All the expenses are duly approved by the Board, disclosed in the Annual Financial Statement of the Company and audited by the Statutory Auditors.

4.3.4. Further, IWA submitted an undertaking signed by CEO and Principal Officer on compliance of applicable arm’s length principles, compliance of relevant provisions of Companies Act, 2013 etc.

4.4. Decision on Charge- 2

The submissions of the IWA are taken on record and the charge is not pressed further.

5. Charge-3 (Observation-3)

5.1. Violations of  Clause f of Form V under Schedule VIII read with regulation 32 of IRDAI (Insurance Web Aggregators) Regulations, 2017.

5.2. Inspection Observation-3

Clientele of paisabazaar.com are diverted to policy bazaar. While browsing the website of Paisabazaar.com, a website operated by its group company M/s Paisabazaar Marketing and Consulting Private Limited (paisabazaar.com), it is noticed from the homepage of Paisabazaar.com, that there is a provision for diverting their clientele for life and health insurance needs to IWA website. This requires the approval of the Authority for diversion of clientele. However, the IWA has not sought any approval of the Authority.

5.3. Summary of IWA’s Submissions:

5.3.1. IWA submitted that it is not a diversion in any material sense as every activity of sale is done only on the Company’s website, hence the approval of the Authority was not considered. Moreover, this is purely a digital insurance marketing (not the solicitation) activity which is a common practice across insurance players for customer outreach.

5.3.2. Further, Paisabazaar does not share any customer details such as name, number, age, gender, etc. with the IWA and at no point of time, is the clientele deliberately forced to view insurance plans against their assent or move to IWA.

5.3.3. In this regard the IWA has submitted an undertaking stating that there is no transfer of personal data from Paisabazaar to IWA portal policybazaar.com and also no payment/s have been made by the IWA to Paisabazaar with regard to the said charge.

5.4. Decision on Charge- 3

The submissions of the IWA are taken on record and the charge is not pressed further.

6. Charge-4 (Observations 4 & 7)

6.1. Violations of –

a) Clause c of Form Q under Schedule IV read with regulation 26 of the IRDAI (Insurance Web Aggregators) Regulations, 2017;

b) Clause b(ii) of Form P of schedule IV read with Regulation 31 of IRDAI (Insurance Web Aggregator) Regulations, 2017;

c) Clause b of Form V of schedule VIII read with Regulation 32 of IRDAI (Insurance Web Aggregator) Regulations, 2017.

6.2. Inspection Observation-4 and Observation 7

Display of TOP 5 ULIPs products:

6.2.1. The IWA website clearly stated at the time of inspection, top 5 ULIP plans (Bajaj Allianz Goal Assure, Edelweiss Tokyo Wealth Gain+, HDFC Click2 Wealth, SBI Life e-wealth Insurance and ICICI Signature). IWA website displayed only details of ULIP products of five insurance companies while the IWA had agreement other life insurance companies that offer ULIPs.

6.2.2. Using the expression, “Top products” itself denotes ranking of products based on some criteria. Only 5 products of insurers were displayed as “Top products” when the entity has agreement with many life insurance companies that offer ULIPs.

6.2.3. Display of some specific insurance products and plans as ‘Best’ & ‘Top’ (including health & Life insurance companies). It was observed that website of IWA demonstrated some specific plans of some insurers as “Best Life Insurance Plans in India 2020”.

6.2.4. Similarly, under “Health section”, there was mention of “Top plans-health insurance” from 12 insurers in a particular sequence (rating).

6.2.5. In the same way, there are 23 insurers having agreements with the IWA, however IWA had named some products pertaining to 12 insurers as ‘Top plans’.

6.2.6. By showing some particular insurance products of some insurers as “Best” or “Top plans”, it has led to creation of preference and promotion of these insurers and their specific plans only.

6.3. Summary of IWA’s Submissions:

6.3.1. IWA submitted that they have not rated, ranked or endorsed any particular life insurance company or their products. On receipt of the Authority’s observations during on-site inspection, they have immediately taken note of the same and took the page down. Further, IWA assured the Authority that the Company shall be more diligent and careful with its communications in future.

6.3.2. IWA submitted that there were some inadvertent errors with respect to display of some insurers as partners and the same was updated immediately. They have not rated, ranked or endorsed any particular insurance company or their products. Screenshots submitted by the authority are articles which provide generic information about various life and health insurance companies offering health insurance products in India. IWA also submitted that they had explained their services via written articles / content by using phrases such as “Top”/ “Best”.

6.4. Decision on Charge- 4

6.4.1. An IWA shall not rank or compare the products in a manner that seeks to promote one insurer over the other. Words like “best”, “top”, or “No. 1” are not allowed unless based on verified, factual, third-party data disclosed transparently and within the ambit of the regulations. Endorsing one insurer or set of insurers over the others leads to scanty choice for the customer to select the products. It also gives rise to non-transparent manner of displaying the products.

6.4.2. It is not clear on what grounds the IWA displayed the said products as best / top in their category. There was no material that was available to the prospects to make an informed choice. The propensity of misguidance to the prospects becomes much more severe in light of the fact that IWA is the market leader as far as insurance web aggregation is concerned. IWA must have acted with much more prudence and caution to give a wider choice to the prospects by not indulging in favourable rating to limited number of insurers.

6.4.3. Clause b(ii) schedule IV-form P of IRDAI (Insurance Web Aggregator) Regulations, 2017 prohibits the IWA from displaying any sort of advertisements either pertaining to any product or service etc., the IWA has effectively advertised for the five insurers whose ULIP products were displayed as top ranked. Further, clause (b) of Form V requires that the IWA shall prominently display the names of the insurers with whom it has an agreement.

6.4.4. By ranking the ULIP plans of only five insurance companies while having agreements with other than these five companies for distribution / solicitation of insurance business, IWA violated the Clause c of Form Q under Schedule IV read with regulation 26 of the IRDAI (Insurance Web Aggregators) Regulations, 2017 and clause b (ii) of Form P of schedule IV of IRDAI (Insurance Web Aggregator) Regulations, 2017 which provides that “Insurance Web Aggregators shall not display ratings, rankings, endorsements or bestsellers of insurance products on their website. The content of the websites of the Insurance Web Aggregators shall be unbiased and factual in nature; they shall desist from commenting on insurers or their products in their editorials or at any other location in their websites”.

6.4.5. Similarly, designating 24 plans of some insurers as ‘Best Life Insurance Plans in India 2020’ and mention of ‘Top plans – Health Insurance’ from 12 insurers can be nothing but promoting a set of products of Insurers offering favourable terms to the IWA.

6.4.6. As it is displayed on their website and the IWA carrying the Certificate of Registration issued by the Authority, the prospects rely on the information and ranking displayed on their website. It can influence the choices of the consumers. Having no informed choices, consumer can be easily misled resulting into serious financial losses to them.

6.4.7. IWA’s submission that as part of their efforts to increase insurance penetration and to provide information relating to insurance products available in the market to the visitors of website, they have quoted best or top Products based on google / bing searches is not acceptable since the regulations clearly state that rating, best sellers, ranking etc. shall not be used at the website of IWA including editorials or other places of the website.

6.4.8. In view of the above, in exercise of the powers vested under Section 102 of the Insurance Act, 1938, the Authority hereby imposes a penalty of Rs. One Crore for the violation of Clause c of Form Q under Schedule IV read with regulation 26 of the IRDAI (Insurance Web Aggregators) Regulations, 2017 and clause b(ii) of Form P of schedule IV read with regulation 31 and clause (b) of Form V of Schedule VIII read with regulation 32 of IRDAI (Insurance Web Aggregator) Regulations, 2017.

7. Charge-5 (Observation – 5)

7.1. Violations of –

a) Regulation 30(b)(ii) and (iv) of IRDAI (Insurance Web Aggregators) Regulations, 2017;

b) Clause 1(b) of Form U under Schedule VII read with regulations 2(j) and 30 of IRDAI (Insurance Web Aggregators) Regulations, 2017.

7.2. Inspection Observation-5

7.2.1. Outsourcing Agreements entered into by the IWA are not in line with regulations, particularly to Regulation 30 of IRDAI (Insurance Web Aggregator) Regulations, 2017 on the pay-outs received by IWA from various insurers. To explain, the following instances may be seen:

i. No specific outsourcing services were mentioned in the agreements with nine insurers;

ii. No specific amount is stated in the agreements with four insurers;

iii. No specific service and no amount for services stated in the agreements with three insurers;

iv. No scope for outsourcing stated in the agreements with three insurers;

v. The agreement entered into with one insurer is for pre-sales services which is not permitted by the extant regulations;

vi. In the case of one insurer, the agreement is exclusively for outsourcing which is not allowed by the extant regulations;

vii. In majority of the agreements, the charges are levied on per seat basis without taking into cognizance the cost-benefit analysis;

viii. Wherever fixed per seat basis amount is agreed, the amount varies insurer to insurer for same type of services. Some insurers are charged at Rs. 50,000 per seat, some charged at Rs. 40,000 per seat, some at Rs. 35,000 per seat and so on;

7.2.2. IWA has received payouts on account on outsourcing activities from 26 insurers. The said payouts for FY 2017-18, 2018-19 and 2019-20 is Rs. 81.90 crore, 151.84 crore and 255.96 crore respectively.

7.2.3. As evident from the above, a significant amount has been earned by the IWA through outsourcing activities which is expected to be an ancillary activity that too only for the post sale services rendered for the policies sourced only through IWA. However, the service level data is not maintained / provided by the IWA. While IWA regulations requires that the agreements should include “charges for services” as a part of the agreement, the IWA has failed to provide the type of service and failed to provide service level data.

7.2.4. Further, in case of the four insurers, the IWA has failed to define or list out the scope of services” in the agreement:

7.2.5. IWA while entering into agreement with HDFC Life for providing outsourcing, has agreed the price on per service basis. IWA has received a sum of Rs. 104.59 crore towards outsourcing charges in the year 2019­20. In one invoice, the IWA has charge a sum of Rs. 24.81 crore towards cost of work station for the month of March, 2020.

7.3. Summary of IWA’s Submissions:

7.3.1. IWA submitted that the Company has received all commission / rewards as per the limits specified by IRDAI. Amount received by the Company as outsourcing fees/charges are reasonable charges as agreed between both the parties as per the terms of the agreement. Regulation 30(b)(iv) of the IRDAI IWA Regulations does not state that the service charges to be charged individually i.e. per service basis.

7.3.2. The manner of charging for outsourcing services on per workstation basis is in line with existing market practices only.

7.3.3. The practice of charging on per resource / per workstation model for rendering outsourcing services through tele-calling mode by third party call centres is a common practice across industry. Further, Regulations do not have the limitation of minimum or maximum services as that is left to be a commercial and value based decision to be taken by the service seeker and service provider.

7.3.4. During the personal hearing, IWA submitted that for all the outsourcing arrangements are done on the basis of legal agreements, charges are pre­determined and for the post-sale activities only. As majority of the policies sold by them are monthly mode policies which require a lot of servicing at their end.

7.3.5. Post personal hearing, the IWA submitted that currently, all the outsourcing arrangements have been stopped.

7.4. Decision on Charge- 5

7.4.1. Regulation 30(b)(ii) entitles an IWA for remuneration for the leads which are converted into sale of insurance policies. Regulation 30(b)(iv) allows the IWAs to undertake outsourcing only in relation to the policies procured by them. Form U, Clause 1(b) makes it mandatory that Insurers and IWAs shall clearly describe all material aspects of the outsourcing arrangement including charges for services, the rights, responsibilities and expectations of all the parties. Not mentioning the scope of services is violation of Forum U Clause 1(b) as mentioned above. Not charging payments on per service basis and charging the payments on “per seat” basis without entailing the number of services / transactions / calls undertaken raises serious concerns over the reasonability of such payments which is a regulatory requirement under Regulation 30 (b)(iv).

7.4.2. The IWA was specifically asked to provide the tele recording of the polices solicited by them in order to ascertain whether the post-sale services were provided only for these policies. However, the IWA has failed to produce such recordings to the Authority even on the sample basis, leading the Authority to conclude that the IWA have earned outsourcing payments even for the policies which were not sourced by them but solicited independently as a telemarketer.

7.4.3. In absence of any recordings, the genuineness of the transactions mentioned in the invoices could not be showcased by the IWA. The per seat payments are made by the insurers for the reason of suo-motu solicitation by IWA acting as a tele-marketer for solicitation of business without basing on the leads generated through their website. IWA can perform outsourcing activities to insurers only limited to those policies which have been solicited by them.

7.4.4. In the absence of specific details of services and amounts thereof in case of four insurers, it is not clear on what basis per seat per month payment was agreed upon.

7.4.5. IWA argument that IRDAI IWA Regulations does not explicitly provide for charging of outsourcing fees at per service rate basis is not tenable as the parties to the outsourcing agreements don’t know, in advance, how many service requests would be received by them in a month so that they can deploy necessary workstations and resources persons to attend the requests so received.

7.4.6. Further, the IWA’s submission during the personal hearing that in some cases servicing is done monthly therefore the number of service requests increases viz a viz the payments, cannot be accepted for the reasons firstly, the approach is counterproductive and disadvantageous for the insurers since they will have to spend much more for monthly premium paying policies; secondly, the IWA themselves have reiterated that the amounts were payable per seat basis and not per service basis. In such case, it does not make a difference whether the post-sale service was on monthly, quarterly, half yearly or yearly basis. The IWA has failed to showcase that for how many monthly mode policies, outsourcing services were utilised.

7.4.7. When the charges are based on work stations, there is a possibility that the insurers end up paying service charges though no single service request is received in a month. Though the regulations have not defined what is ‘reasonable fee’, the fees should be equitable when compared with similar services and the charges prevailing in industry. These activities are normally charged per request / per service basis in the industry. Therefore, Pay-outs made by IWA per seat basis without giving justification with respect to the number of services offered, cannot be considered as reasonable. The services rendered by the Web Aggregators are limited, the remuneration should be reasonable and for the services rendered. Irrespective of the parameter – i.e., per seat basis or per transaction basis, the rate at which the services are rendered should be reasonable. To assess the reasonability, the payments made should be in proportion to the volume of transactions involved. In case of many insurers, even the scope and type of services offered was not clear. This is clearly in violation of Regulation 30 (b) (iv) of IRDAI (Insurance Web Aggregators) Regulations, 2017 which prescribes that “reasonable service charges” are to be paid by the Insurers to the Web Aggregators.

7.4.8. IWA has failed to provide a clear and adequate explanation for the substantial payments received from insurance companies. The lack of justification raises concerns about the transparency and legitimacy of these transactions. IWA is expected to demonstrate the reasonableness of such payments, ensuring that they align with industry norms and regulatory expectations. Without proper clarification, the nature and purpose of these payments remain unclear, which could potentially indicate a gap in financial oversight or compliance.

7.4.9. In view of the above, in exercise of the powers vested under Section 102 of the Insurance Act 1938, the Authority hereby imposes a penalty of Rs. One Crore for the violation of Regulation 30(b)(ii), Regulation 30(b)(iv) and Clause 1(b) of Form U of Schedule VII read with regulation 2(j) and 30 of IRDAI (Insurance Web Aggregators) Regulations, 2017.

8. Charge-6 (Observation – 6)

8.1. Violations of –

a) Regulation 10 (f) of IRDAI (Insurance Web Aggregator) Regulations, 2017;

b) Clause b of Form O of schedule IV read with Regulation 25 of IRDAI (Insurance Web Aggregator) Regulations, 2017;

c) Authority’s circular number IRDA / INSP / CIR / ONS / 157 / 09 / 2018 dated 19th September 2018.

8.2. Inspection Observation-6

8.2.1. It is observed that the premium register submitted for life business does not show correct mapping of Authorized Verifiers (“AV”). The policies wise details of policies sold via “Telemarketing mode” should have been tagged by Authorized Verifiers in line with regulatory framework.

8.2.2. However, it was observed that it was incomplete wherein 97,780 policy records were mapped as “unassisted” or “unmapped” out of total records of 4,32,366 policies sold through Telemarketing Mode.

8.2.3. There was no tagging of individual policy with the ‘Authorized Verifier’ in the Lead Management System (LMS) and hence couldn’t be ascertained as to who actually concluded the sale of policy.

8.2.4. In addition, the IWA failed to provide solicitation related documents including call recording even for a single policy to establish whether sale has been concluded by Authorized Verifier or not.

8.3. Summary of IWA’s Submissions:

8.3.1. IWA submitted that there are practical challenges with the tagging process. For instance, tagging of a policy to one particular authorized verifier is not practically feasible.

8.3.2. Company has consistently worked upon strengthening their AV Tagging system and has fully implemented the AV tagging process effective April, 2019.

8.3.3. The IWA, as advised during the personal hearing, submitted the year-wise total number of policies sold and the corresponding total number of authorised verifiers for the last five years starting from the period of inspection as under:

Life Insurance Business

FY Year	No. of Assisted Policies	No. of Authorized Verifiers
FY-20	2,37,815	3,297
FY-21	2,36,922	1,976
FY-22	2,58,438	1,583
FY-23	3,07,599	2,484
FY-24	3,81,515	2,361

General Insurance Business

FY Year	No. of Assisted Policies	No. of Authorized Verifiers
FY-20	10,20,306	2,217
FY-21	12,48,146	1,794
FY-22	12,07,215	1,444
FY-23	13,39,151	1,813
FY-24	17,20,859	1,859

8.3.4. The data submitted by the IWA, for both Life and Non-Life insurance policies, indicates that the more policies were assisted by the lesser number of Authorised Verifiers. The above figures show that the data of AVs are gradually decreasing in Non-Life cases while the more policies are being solicited / assisted by the IWA.

8.4. Decision on Charge- 6

8.4.1. Regulation 10(f) of IWA Regulations, 2017 makes it mandatory for the IWA to maintain policy wise and AV wise details wherein each policy solicited by the IWA is tagged to the AV. IWA Regulations also cast an obligation on IWA to maintain data in such a way that the Authority can have regular and timely access to it.

8.4.2. At the time of inspection, IWA failed to provide the number of policies sold without tagging the same with the AV for the FYs 2017-18, 2018-19 & 2019-20 to address the regulatory concern that they solicited and procured potentially reasonable number of insurance policies commensurate with their resources and the number of AV engaged by them. It gives rise to suspicion whether these policies were actually sourced by IWA within the permissible regulatory framework.

8.4.3. IWA failed to have a Standard Operating Procedure (SOP) and act according to the same. Failure of the IWA to provide the data sought to the Authority within a given timeline also raises regulatory concerns and serious questions over the policies solicited by them.

8.4.4. The IWA response is silent about the inspection team’s observation regarding tagging of general insurance and health insurance policies to the AV.

8.4.5. The IWA was required to maintain records in the format specified by the Authority which shall capture policy-wise and authorised verifier-wise details wherein each policy solicited by the insurance Web Aggregator through the authorised verifier is tagged to that authorised verifier. The insurance Web Aggregator shall put in place systems which allow regular access to such records and details by the Authority.

8.4.6. The IWA was required to tag every insurance policy sold by the Authorised Verifier to his identity for tracking sales and complaints if any which shall be given access to the Authority on remote basis in terms of clause b of schedule IV-Form O of IRDAI (Insurance Web Aggregator) Regulations, 2017. IWA failed to submit the data of AVs to the inspection team thus violating Authority’s circular number IRDA / INSP / CIR / ONS / 157 / 09 / 2018 dated 19th September 2018.

8.4.7. In view of the above, in exercise of the powers vested under Section 102 of the Insurance Act 1938, the Authority hereby imposes a penalty of Rs. One Crore for the violation of Regulation 10(f) and Clause b of Form O of schedule IV read with regulation 25 of IRDAI (Insurance Web Aggregator) Regulations, 2017.

8.4.8. Further, the IWA is advised –

i. to ensure that each policy solicited through on-line platform is compulsorily tagged to the respective AV.

ii. to put in place systems which allow regular and prompt access to such records and details to the Authority.

9. Charge- 7 and Charge- 9 (Observation-8 & 13)

9.1. Violations of –

a) Section 64 VB (4) of Insurance Act, 1938;

b) Clause a (v) Form P of schedule IV read with regulation 31 of IRDAI (Insurance Web Aggregator) Regulations, 2017;

c) Clause 1(a)(vi) of Form X of Schedule IX read with regulation 33 of IRDAI (Insurance Web Aggregators) Regulations 2017;

d) Clause 2, 4(a), 4(b) & 5 of the Authority’s circular number IRDA/INSP/CIR/ONS/157/09/2018 dated 19th September 2018;

e) Clause 3(iii) of the IRDA Circular no. IRDA/Life/Misc./Cir/106/05/2015 dated 17th May 2015.

9.2. Inspection Observation 8 & 13:

9.2.1. It is observed that IWA had collected insurance premium on behalf of insurers without being authorized by them.

9.2.2. IWA is mostly using its own payment gateway and its own Nodal Account for the transmission of insurance Premium to Insurance companies without having the IRDAI approval.

9.2.3. The details of the insurance premium collected and remitted through the Nodal Account of IWA is as under:

i) For 2019-20, remitted Rs.1671.24 crore to the insurers, which is approximately 95 percent of total insurance premium.

ii) For 2018-19, remitted Rs.1012.44 crore to the insurers, which approximately 89.01 percent of total insurance premium remittance.

iii) For 2017-18, remitted Rs.473.07 crore to the insurers, which approximately 88.24 percent of total insurance premium remittance.

9.2.4. From the above, it is evident, that the IWA is mostly using its own payment gateway and its own Nodal Account for collecting the premium and the minimum working days required to remit such insurance premium is 3 working days whereas as per Section 64VB of the Insurance Act, 1938 read with Clause 3(iii) of the IRDA Circular no. IRDA / Life / Misc. / Cir / 106 / 05 / 2015 dated 17th May 2015, the insurance intermediaries are required to remit the insurance premium within 24 hours of the receipt of the premium.

9.2.5. It is also resulting in the delays of the remittance of insurance premium to the insurers. On the examination of the selected 67 insurance policies, the delay noticed in remittance of insurance premium exceeded by more than 30 days. Further, for 8971 sample insurance policies, delay in the remittance of insurance premium was ranging from 5 days to 24 days. Further, for another set of around 77033 policies, the premium has been remitted after 3 working days.

9.3. Summary of IWA’s Submissions:

9.3.1. IWA submitted that they have only collected insurance premium on behalf of the insurers based on specific authorization from them using RBI registered payment gateways.

9.3.2. In the given case, the insurer vide its letter dated 6th June, 2016 had issued a specific authorization on its letterhead to the Company for collection of insurance premium with respect to policies sourced through Company’s designated website on its behalf.

9.3.3. IWA submitted that IRDAI IWA regulations allow IWA to collect insurance premium in an online mode on behalf of the insurers subject to a specific authorization. RBI Circular stipulates the settlement cycle as “T+3” involving nodal accounts. The collection of premium by a web aggregator is dependent on the systems and technologies of third parties such as banks and other ecosystem partners. IWA further submitted that the provision of Section 64VB (4) of the Insurance Act does not envisages digital payments and emerging technological challenges with the advancement of digital payments.

9.3.4. During personal hearing, IWA submitted that they don’t have any control over the premium or access to the premium. For more than 99% of the policies, premium is remitted within 24 hours and the amount is remitted as per RBI guidelines and Section 64 VB of Insurance Act, 1938 barring some exceptions. They are working with payment gateways to ensure the remittance of premium within 24 hours excluding bank holidays. They are committed to exploring and enabling the possibility of maintaining float account with the insurer to remit the premium within 24 hours.

9.4. Decision on Charge-7 & 9

9.4.1. The IWA’s submission that RBI vide its Circular dated 24th November 2009 allows settlement cycle as “T+3” for online remittances is not acceptable in view of specific legal provision (Section 64VB) in Insurance Act, 1938 read with Clause 3(iii) of the IRDA Circular no. IRDA/Life/Misc./Cir/106/05/2015 dated 17th May 2015 applicable to insurance sector which requires the intermediaries to remit the premium collected from the clients to insurance companies within 24 hours (excluding holidays).

9.4.2. An intermediary does not have any right over the insurance premiums, therefore, the premiums are required to be timely remitted to the respective parties to ensure the coverage and payment of claims and thus protect the interest of the policyholders. Section 64VB (1) mandates that no insurer can assume risk unless premium is received in advance. These are the reasons an IWA is not expected to sit on monies beyond a reasonable time and such delayed remittance poses a systemic risk to entire insurance eco system.

9.4.3. The regulations permit only RBI-authorized payment gateways for processing transactions. However, this does not exempt IWA from complying with Section 64 VB (4) of the Insurance Act, 1938 read with Clause 3(iii) of the IRDA Circular no. IRDA / Life / Misc. / Cir / 106 / 05 / 2015 dated 17th May 2015. In any case the premium should have been remitted within 24 hours, as per the requirements. However, IWA failed to do so.

9.4.4. In view of the above, in exercise of the powers vested under Section 102 of the Insurance Act 1938, the Authority hereby imposes a penalty of Rs. One Crore for the violation of Section 64 VB (4) of the Insurance Act, 1938 and Clause 3(iii) of the IRDA Circular no. IRDA/Life/Misc./Cir/106/05/2015 dated 17th May 2015.

9.4.5. Further, IWA is advised to take necessary steps to ensure compliance of Section 64VB of the Insurance Act, 1938.

10. Charge-8 (Observation 10)

10.1. Violations of –

a) Clause 5(a) and 5(d) of Form T of schedule VI read with regulation 29 of IRDAI (Insurance Web Aggregator) Regulations, 2017;

b) Authority’s circular number IRDA / INSP / CIR / ONS / 157 / 09 / 2018 dated 19th September 2018 by not providing information to the inspection team.

10.2. Inspection Observation -10 (Charge 8)

Non maintenance of call recordings and adequate solicitation related documents. Despites of reminder, IWA failed to provide call recoding even for a single case. This indicate that the systems are not administratively capable to extract solicitation related documents w.r.t. policies sold to demonstrate the process.

10.3. Summary of IWA’s Submissions:

10.3.1. IWA submitted that all call records are duly maintained by the Company as per the regulatory requirements and that the Company has duly submitted the records of the sample calls as requested by the Inspection team.

10.3.2. They have put in place systems to fulfil the regulatory requirements and comply with maintenance of call recording and solicitation related documents as per the provisions of IRDAI WA Regulations. The access to data may take time for retrieval however, that does not mean that the data does not exist or is inaccessible.

10.4. Decision on Charge- 8

10.4.1. There is a concern that IWA could be indulging in sourcing of business through call centers by way of misleading calls. There may be issues of mis-selling however, the same couldn’t be verified by the inspection team as they could not get access to the data. The inability to provide the data within turn-around-time is a matter of concern from suitability point of view and from the stand-point of treating customers fairly.

10.4.2. Lag in retrieval of data does affect customer service, regulatory turnaround times and is non-compliance with the spirit of regulation.

10.4.3. In view of the above, the IWA is cautioned for the lapse and directed to carry out the audit of the process put in place in this regard and submit a certificate from CA firm that call records are maintained by IWA and are in retrievable format. The said audit shall be carried out for last three financial years starting from 2021-22.

11. Charge-10 (Observation – 14)

11.1. Violations of Regulation 5(c) of the IRDAI (Payment of Commission or Remuneration or Reward to Insurance Agents and Insurance Intermediaries) Regulations, 2016.

11.2. Inspection Observation-14

Web Aggregator has received the insurance commission in excess of the remuneration prescribed under the commission Regulations. In 8 sample cases, IWA has exceeded the limit of 15 percent as prescribed under the Regulations.

11.3. Summary of IWA’s Submissions:

11.3.1. IWA submitted that the prior to the notification of the rates prescribed in the Commission Regulations, 2016, the rates specified under IRDAI Circular on “Limits on payment of commission or brokerage on general insurance business” of 25th August, 2008 (“Circular”) were applicable for health insurance products. As per the said Circular, the category for “All Other Business” covers Health Insurance products and it mandated that the maximum percentage of premium payable as commission (excluding service tax) for Health Insurance Products was limited at 17.5%. The commission limit of 17.5% was revised to 15% under the Commission Regulations, 2017 which was applicable for health Insurance products from 1st April, 2017 onwards.

11.3.2. During personal hearing, IWA submitted that there were total 514 policies and in only 2 policies, commission is wrongly received as 17.5% instead of 15%. The delay in the invoice was due to reconciliation reasons.

11.4. Decision on Charge-10

IWA is cautioned for the lapse and is advised to comply with the extant guidelines / regulations issued by the Authority from time to time.

12. Charge-11 (Observation – 21)

12.1. Violations of –

a) Regulation 3 (a) (iv) of IRDAI (Insurance Web Aggregators) Regulations, 2017;

b) Clause 7 of Undertaking under Form G of Schedule II read with Regulation 13 of IRDAI (Insurance Web Aggregators) Regulations, 2017.

12.2. Inspection Observation-21

12.2.1. It was observed that many of the Authorized Verifiers of IWA were holding valid insurance agency license in their individual capacity. A list of some findings on the same is placed below:

Name	Designati on	Employ ee Code	Date of Joining	PAN Number	Insurer	Status as per IRDAI Website	Annexu re No.
Neeraj Jha	Sales Consultant	PW0041 9	1-10-2015	AYOPJ26 92R	LIC	In Force	05
Rohit Mishra	Senior Associate	PW0068 0	1-10- 015	CJUPM98 82M	Bharti AXA Gen	In Force	06
Tahir Husean	Associate  SalesConsultant	PW0088 9	1-11-2015	AMBPH95 83N	Bharti AXA Gen	In Force	07
Dharmend er Kumar	Senior TeamCoach	PW0097 8	1-11- 015	DQEPK97 79M	Bharti AXA Gen	In Force	08
Preeti	Senior Team Coach	PW0045 6	1-10-2015	BCCPP02 38C	Kotak Mahindra Life	License Terminat ed on 22- 10-2016	09
Observation: Ms. Preeti joined the WA on 1-10-2015 and her Agency License was terminated on
22-10-2016, which means she was running her Agency for almost one year after
joining the WA Company.
Sushant Gaba	Senior Team Coach	PW0048 0	1-10-2015	ATVPG29 82M	Kotak Mahindra Life	License Terminat ed on 21- 12-2016	10
Observation:  Mr. Sushant Gaba joined the WA on 1-10-2015 and his Agency License was
terminated on 21-12-2016, which means he was running his Agency for almost 14
months after joining the IWA.

–

Name	Designati on	Employ ee Code	Date of Joining	PAN Number	Insurer	Status as per IRDAI Website	Annexu re No.
Kavita	Subject Matter Expert	PW0056 1	1-10-2015	BNUPK83 99A	Kotak Mahindra Life	terminate d on 21-12-2016	11
Observation: Ms. Kavita joined the WA on 1-10-2015 and her Agency License was terminated on
21-12-2016, which means she was running her Agency for almost 14 months after
joining the IWA.

12.2.2. The IWA is having about 6135 Authorized Verifiers (AVs) as on date. Above is the result of checking about 120 AVs. The IWA have failed to system in place to check whether any of AV have any insurance agency during the course of employment with them.

12.3. Summary of IWA’s Submissions:

12.3.1. IWA submitted that the deduplication of sample cases as quoted by the Authority in its observation is of the year 2015-16. Further, the IWA has stated that it was only during the on-site inspection, it was brought to the knowledge of the IWA that PAN Numbers of AVs can also be examined using the “PAN Look Up facility” as available on www.irdaonline.org. IWA further submitted that the Company has also cautioned the employees for failure to disclose the said fact and to adhere to the code of conduct policy of the Company, going forward.

12.3.2. During personal hearing, IWA submitted that they have taken several steps to strengthen their due diligence process. Now they are checking both ENVOY portal and PAN Lookup portal. Some of their employees become the insurance agent of insurance companies without informing Policybazaar and that insurance company did not check from their end whether that person is already holding agency license. Insurance company also didn’t act upon the said individual even if the issue is brought to their attention by the IWA. They take the suitable action against said employee at their end.

12.3.3. The IWA also submitted that over and above, the company has enhanced its governance framework and strengthened its process to ensure that the details of its sales staff are duly verified from the online database of the Authority a regular basis.

12.4. Decision on Charge- 11

12.4.1. IWA did not conduct proper due diligence on their employees and instead relied on the employees to disclose the information themselves. This highlights a deficiency in the internal controls and operational processes of IWA, reflecting lapses in their due diligence procedures.

12.4.2. IWA is cautioned for the lapse and is advised to comply with the extant guidelines / regulations issued by the Authority from time to time.

13. Summary of Decisions:

Charge. No.	Violation of Provisions	Decision
1	(i) Clauses 1(i), 2 and 3 (ii) of Form N under Schedule III read with regulation 23 of IRDAI (Insurance Web Aggregators) Regulations, 2017; (i) Regulation 2(l) of IRDAI (Insurance Web Aggregators) Regulations, 2017: and (i) Clause 5 of Form G under Schedule II read with regulation 13 of IRDAI (Insurance Web Aggregators) Regulations, 2017.	Penalty of Rs. One Crore
2	(i) Clauses b(iii)(a)(1) and b(iii)(a)(2) of Form P under Schedule IV read with regulation 31 of the IRDAI (Insurance Web Aggregators) Regulations, 2017; (i) Clause 1(a) (iv) of Form X under Schedule IX read with regulation 33 of  the IRDAI  (Insurance WebA ggregators) Regulations, 2017; (i) Regulation 2(k) of IRDAI (Insurance Web Aggregators) Regulations, 2017.	Charge is not pressed
3	Clause f of Form V under Schedule VIII read with regulation 32 of IRDAI (Insurance Web Aggregators) Regulations, 2017.	Charge is not Pressed
4	(i) Clause c of Form Q under Schedule IV read with regulation 26 of the IRDAI (Insurance Web Aggregators) Regulations, 2017;(ii)  clause b(ii) of Form P of schedule IV read with regulation 31 of  the IRDAI  (Insurance Web Aggregators) Regulations, 2017; and(iii) clause (b) of Form V of Schedule VIII read with regulation 32 of IRDAI (Insurance Web Aggregator) Regulations, 2017.	Penalty of Rs. One Crore
5	(i) Regulation 30(b)(ii) of IRDAI (Insurance Web Aggregators) Regulations, 2017; and (ii) Clause 1(b) of Form U of Schedule VII read with regulation 2(j) and 30 of IRDAI (Insurance Web Aggregators) Regulations, 2017.	Penalty of Rs. One Crore
6	(i)  Regulation 10(f) regulation 25 of IRDAI (Insurance Web Aggregator) Regulations, 2017; and (ii)Clause b of Form O of schedule IV read with regulation 25 of IRDAI (Insurance Web Aggregator) Regulations, 2017.	Penalty of Rs. One Crore and Advisory
8	(i) Clause 5(a) and 5(d) of Form T of schedule VI read with  regulation 29 of IRDAI (Insurance Web Aggregator) Regulations, 2017; and (i) Authority’s circular number IRDA / INSP / CIR / ONS / 157 / 09 / 2018 dated 19th September 2018 by not providing information to the inspection team.	Caution and Direction
10	Regulation 5(c) of the IRDAI (Payment of Commission or Remuneration or Reward to Insurance Agents and Insurance Intermediaries) Regulations, 2016.	Caution and Advisory
11	(i) Regulation 3 (a) (iv) of IRDAI (Insurance Web Aggregators) Regulations, 2017; and(ii)  Clause 7 of Undertaking under Form G of Schedule II read with Regulation 13 of IRDAI (Insurance Web Aggregators) Regulations, 2017.	Caution and Advisory

14. The penalty amount of Rs. 5 Crores (Five Crores) shall be remitted by the IWA within a period of forty-five days from the date of receipt of this order through NEFT / RTGS (details for which will be communicated separately). An intimation of remittance may be sent to Shri Sanjay Kumar Verma, General Manager (Enforcement & Compliance) at the Insurance Regulatory and Development Authority of India, Survey No. 115/1, Financial District, Nanakramguda, Hyderabad 500032, email id enforcement@irdai.gov.in with a copy to accounts@irdai.gov.in

15. Further,

a) The Order shall be placed before the Board of the IWA in the upcoming Board Meeting and the IWA shall provide a copy of the minutes of the discussion.

b) The IWA shall submit an Action Taken Report to the Authority on direction given within 90 days from the date of this Order.

16. If the IWA feels aggrieved by this Order, an appeal may be preferred to the Securities Appellate Tribunal as per the provisions of Section-110 of the Insurance Act, 1938.

Satyajit Tripathy
Member (Distribution)

P K Arora
Member (Actuary)

Place: Hyderabad
Date: 4^th August, 2025