INDIA Law and Practice Contributed by: Neeraj Tuli, Celia Jenkins and Rajat Taimni, Tuli & Co
statutory simplifications and partly due to new risks emerging through innovations in other industries. While the industry has been typically slow to adapt and embrace new trends in terms of product offerings, new products have been filed in terms of: • index-linked life insurance products; • long-term insurance covers; • health insurance covers for mental illness; • standard life insurance products; • telematics-based riders; • specific endorsements for data protection and impersonation frauds (which even cover the result- ant fund transfers) in both cyber- and crime insur- ance; and • a new range of fitness and wellness-focused prod- ucts in the health sector. 12. Developments in Insurance Law 12.1 Significant Legislative or Regulatory Developments Products The IRDAI has notified the Products Regulations, along with the corresponding master circulars on life, health, and general insurance products, which set out revised norms vis-à-vis the design and issuance of life, health and general insurance policies. The Prod- ucts Regulations aim to enhance insurance innova- tion, encourage adoption of good governance, and ensure effective governance and oversight in product design and pricing. Product Filing Procedures In 2024, the IRDAI introduced many changes in the procedure for product filing for all lines of insurance products, as follows. • General insurance products – the IRDAI has issued the IRDAI’s Master Circular on General Insurance Business of 11 June 2024 (the “General Master Circular”), which repeals the earlier circulars on product filing of general insurance products and provides that all general insurance products will be introduced or modified through the “use and file” procedure.
• Health insurance products – the IRDAI has issued the Health Master Circular, which provides that all categories of health insurance products and riders are to be introduced or modified through the “use and file” product filing procedure. • Life insurance products – the IRDAI has issued the IRDAI’s Master Circular on Life Insurance Products 2024 of 13 June 2024 (the “Life Master Circular”), which repeals the earlier circulars on product filing of life insurance products. The Life Master Circu- lar specifies that the “use and file” product filing procedure is applicable to certain life insurance products/riders – for example, individual and group non-linked term products, individual and group linked insurance products, group fund-based insurance products, group credit life insurance products, and combi products. In cases where the insurer issues a product that does not fall under the ambit of the “use and file” procedure, the “file Recent years have been significant for the insurance sector, as they have seen the issuance of several regu- lations and guidelines issued by the IRDAI, including the following. • The IRDAI (Maintenance of Information by the Regulated Entities and Sharing of Information by the Authority) Regulations 2025 consolidate and repeal the erstwhile norms on the sharing of confi- dential information concerning regulated entities by the IRDAI, and maintenance of minimum informa- tion by insurers (including FRBs) and insurance intermediaries. • The IRDAI has issued the Insurance Fraud Monitor- ing Framework Guidelines 2025 on 9 October 2025 and use” procedure shall apply. Additional Market Developments (the “Guidelines”), which will take effect from 1 April 2026 and repeal the existing 2013 framework. The Guidelines expand their scope to cover distri- bution channels in addition to insurers and reinsur- ers, introduce new fraud categories ie, “external fraud” and “affinity/complex fraud”, and require insurers to establish a Fraud Monitoring Com- mittee and a supporting Fraud Monitoring Unit. The Guidelines, inter alia, prescribe standardised reporting requirements, mandate the adoption of a strong cybersecurity framework to address cyber
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