Summary: The Insurance Regulatory and Development Authority of India (IRDAI), by its order dated 14 October 2026, rejected the application of M/s Anatoly Insurance Brokers Pvt. Ltd. for registration as a Direct Insurance Broker (Life and General). During scrutiny, IRDAI found that the applicant had not disclosed its promoter Devender Singh’s association with Kaveri Informatics Pvt. Ltd., a corporate agent in which he held a 50% shareholding. He also held 99% of Anatoly’s shares. IRDAI had earlier refused renewal of Kaveri’s registration for regulatory violations, including false information and declarations, a false Chartered Accountant certificate showing positive net worth, and failure to maintain the prescribed minimum net worth. Anatoly submitted that the omission arose from its mistaken belief that Kaveri’s expired registration made the association irrelevant, and that Singh was merely a shareholder without an executive or day-to-day management role in Kaveri. IRDAI found that this explanation did not discharge the obligation to provide complete and accurate material information. It considered the undisclosed association and Kaveri’s regulatory history relevant to assessing the promoter’s fit and proper status under the IRDAI (Insurance Brokers) Regulations, 2018. Exercising its powers under Regulation 12(1), IRDAI rejected the application dated 11 July 2024. The order provides for an appeal to the Securities Appellate Tribunal under Section 110 of the Insurance Act, 1938. If the applicant chooses not to appeal, it may submit a fresh application after one year from the order’s effective date, for consideration on merits.
Insurance Regulatory and Development Authority of India
Ref: IRDAI/INT/ORD/MISC/134/10/2026 | Dated : Date: 14.10.2026
Order of in the matter of M/s Anatoly Insurance Brokers Pvt. Ltd.
1. Based on the
1.1. Show Cause Notice (“SCN”) Ref: IRDAI/DB/ANT/SCN dated 5th June,2026 issued to M/s Anatoly Insurance Brokers Pvt. Ltd (“Anatoly” or “Applicant”) in respect of observed deficiencies in compliance with the provisions of the Insurance Act, 1938, read with the relevant Regulations issued by the Insurance Regulatory and Development Authority of India (IRDAI or Authority).
1.2. Response of Anatoly dated 7th July,2026, to the SCN.
1.3. The submissions presented by Anatoly during the Personal Hearing chaired by Mr. Deepak Sood, Member (Non-Life) and Mr. Swaminathan Iyer, Member (Life), on 17th August, 2026.
2. Background
2.1. M/s. Anatoly Insurance Brokers Pvt. Ltd vide URN BR-NEW-15346-2024 filed an application with the Authortiy for grant of Certificate of Registration (CoR) to act as Direct Insurance Broker (Life and General) in terms of Regulation 3(1)(c) of IRDAI (Insurance Brokers) Regulations, 2018 (hereinafter referred to as “the Regulations”).
2.2. During the processing of the application, it was observed by the Authority that the promoter of the applicant company, Mr. Devender Singh is also a Promoter (50% shareholder) of Corporate Agent by the name of M/s Kaveri Informatics Pvt. Ltd. – CA0527 (hereafter referred to as KIPL / Corporate Agent), however the said information was not disclosed in the application submitted to the Authority.
2.3. Further, the Authority passed an Order vide no. IRDAI/INT/ORD/MISC/137/12/2025 dated 5.12.2025 against M/s Kaveri Informatics Pvt. Ltd. refusing renewal of their Certificate of Registration (CoR) COR on the following alleged charges –
- Submission of false information and false declaration in Form A under Regulation 11 (1) of IRDAI (Registration of Corporate Agents) Regulations, 2015.
- Violation of Regulation 8(1) of IRDAI (Registration of Corporate Agents) Regulations, 2015 – Non-maintenance of regulatory requirements of minimum net worth of Rupees Fifty Lakhs.
2.4. Accordingly, a Show Cause Notice (SCN) Ref: IRDAI/DB/ANT/SCN dated 05.06.2026 was issued to Anatoly as to why the application filed with the Authority for the grant of CoR to act as Insurance Broker should not be rejected in terms of Regulation 12(1) of the Regulations
2.5. Anatoly submitted their response to the SCN vide letter dated 7th July, 2026 wherein they also requested a personal hearing.
2.6. As requested, a Personal Hearing was granted on 17th August, 2026 before the panel of two Whole-Time Members of the Authority – Mr. Deepak Sood, Member (Non-Life) and Mr. Swaminathan Iyer, Member (Life).
2.7. Anatoly was represented by Mr. Mr. Devender Singh (Promoter, Anatoly). On behalf of the Authority, Mr. Prabhat Kumar Maiti – GM, Mr. Mohammad Ayaz – DGM, Mr. A. Rama Sudheer – AGM and Mr. Harsh Pal- AM of Intermediaries Department attended the Personal Hearing.
2.8. The submissions made by Anatoly, their response to the SCN dated 7th July, 2026, submissions made during the Personal Hearing on 17th August, 2026 have been carefully considered by the Authority and are summarised below:
3. Relevant Provisions for consideration of application for grant of Certificate of Registration
3.1. Regulation 7 (5) of the Regulation which reads as: “7. Furnishing of information, clarification and personal representation — (5) The applicant shall bring to the notice of the Authority, on its own forthwith, such further information/or clarification, which might have a bearing on consideration of their application.”:
3.2. Violation of Regulation 8 (1), 8 (2) (d) and 8 (2) (h) of the Regulation which reads as:
“8(1) Consideration of application —
(1) The Authority while considering an application shall take into account, all matters relevant for carrying out of the functions of the insurance broker.
(2) Without prejudice to the provisions of (1) above, the Authority in particular, shall take into account the following, namely: –
3.3. (d) Whether any person, directly or indirectly connected with the applicant, has, in the past, been refused grant of a certificate of registration or license by the Authority.
3.4. (h) Whether the Principal Officer/ Director(s)/ Promoter(s)/ Partner(s)/ Key Management Personnel Are Fit and Proper based on the statement in Schedule I – Form G of these regulations.”
3.5. SCHEDULE I – Form G which inter-alia specifies the following:
“c) All of its promoters /partners / directors are fit and proper persons;
d) All persons having effective control on the applicant are fit and proper persons to carry out the business;
e) All Key Management Personnel of the applicant are fit and proper.”
Further FORM G, inter-alia seeks the following information to be submitted by each individual under ‘Declaration and Undertaking for Principal Officer/Directors/Partners/Promoters/Key Management Personnel:’
“II (c) Have you ever been refused or restricted by any regulatory authority to carry on any business, trade or profession for which a specific license or registration or other authorization is required by law.
II (d) Have you been ever censured or disciplined or suspended or refused permission or license or registration by any regulatory authority to carry on any business activity.
II (m) Have you at any time come to the adverse notice of a regulator such as SEBI, IRDAI, DCA.”
3.6. Observations:
3.6.1. It is observed that the applicant failed to disclose the information regarding the association of its Promoter i.e. Mr Devender Singh with the Corporate Agent (Kaveri) in their application.
3.6.2. Considering the conduct of the Corporate Agent in the matter as brought out in the Authority’s order dated 05.12.2025, mentioned at 2.3 above, and the fact that the Applicant and the Corporate Agent are having a common promoter Mr. Devender Singh (with 50% stake in Corporate Agent and 99% in Applicant Company), who by virtue of the action taken against the Corporate Agent are found not to be “Fit and Proper”.
3.7. Summary of Anatoly Submissions:
3.7.1. Anatoly submitted that they proceeded under the mistaken and flawed impression that since KIPL’s Corporate Agency registration already stood expired as on the date of application, the said registration and Mr. Devender Singh’s shareholding therein were no longer relevant or material to the consideration of the present application for a Direct Insurance Broker licence. It was this erroneous understanding and not any design to withhold or misrepresent facts that led to the non-disclosure of Mr. Devender Singh’s name and his association with KIPL in Form A/Form G filed with the application.
3.7.2. Moreover, Mr. Devender Singh does not hold any Executive position in KIPL and that he is neither involved in day-to-day operations of the Organisation nor he has substantial control over day-to-day management of the Company and his role is limited as shareholder of the Company.
3.8. Issues / concerns:
3.8.1. The Applicant has admitted that it did not disclose the association of its Promoter, Mr. Devender Singh, with KIPL in the application submitted to the Authority. The Applicant has attributed the omission to a mistaken understanding that, since KIPL’s Corporate Agency registration had expired as on the date of the application, the association was no longer relevant or material. However, this explanation does not absolve the Applicant of its obligation to furnish complete and accurate information relevant to the Authority’s consideration of the application.
3.8.2. The omission is therefore considered material and substantive in nature, as it related directly to the background, regulatory history and fit and proper assessment of a Promoter having overwhelming shareholding (i.e. 99%) in the Applicant Company.
3.8.3. Moreover, the Order passed against M/s Kaveri Informatics Pvt. Ltd. refusing renewal of their Certificate of Registration (CoR) on the submission of false information and false declaration in Form A, including submission of a false Chartered Accountant certificate showing positive net worth, as well as failure to maintain the minimum net worth prescribed under Regulation 8(1) of the IRDAI (Registration of Corporate Agents) Regulations, 2015 reflects serious deficiencies concerning the entity’s regulatory compliance, financial integrity and candour in its dealings with the Authority. The aforesaid findings are material in the context of the fit and proper assessment of persons associated with the Applicant, particularly considering that Mr. Devender Singh held a substantial 50% shareholding in M/s Kaveri Informatics Pvt. Ltd. and holds 99% shareholding in the Applicant Company.
4. Decision:
4.1 The Authority has considered the application, the submissions made by the Applicant and the material available on record. It is noted that the renewal of the Certificate of Registration of M/s Kaveri Informatics Pvt. Ltd. was refused by the Authority on account of serious regulatory violations, including submission of false information and false declaration in Form A and submission of a false Chartered Accountant certificate showing positive net worth, as well as failure to maintain the prescribed minimum net worth.
4.2 It is further noted that Mr. Devender Singh, who holds 99% shareholding in the Applicant Company, also held 50% shareholding in M/s Kaveri Informatics Pvt. Ltd. This association is material for assessing his fit and proper status. The Applicant was also required to disclose such material information to the Authority. However, the same was not disclosed in the application.
4.3 The explanation that the association was not disclosed as the registration of M/s Kaveri Informatics Pvt. Ltd. had expired does not satisfactorily address the concerns regarding his status as being Fit & Proper. Accordingly, the Authority is not satisfied that the Applicant meets the fit and proper requirements for grant of registration and, therefore, the Authority is of the view that the application submitted by the Applicant does not satisfy the conditions above set out in the Regulations for grant of certificate of registration.
4.4 Accordingly, in exercise of the powers vested upon the Authority under sub regulation (1) of regulation 12 of the Regulations, the Authority hereby rejects the application dated 11th July,2024 filed by M/s Anatoly Insurance Brokers Pvt. Ltd.
4.5 If the Broker is aggrieved by this Order, an appeal may be preferred before the Securities Appellate Tribunal in accordance with the provisions of Section 110 of the Insurance Act, 1938.
4.6 As per Regulation 12(3) of the Regulations, if the applicant chooses not to appeal against the order of rejection of application, the applicant may make a fresh application for issuance of certificate of registration after lapse of one year from effective date of such Order for consideration by the Authority. The Authority may consider such application on merit.
Deepak Sood
Member (Non-Life)
Swaminathan Iyer
Member (Life)
