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Registration of Insurance Web Aggregator in India

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Introduction

An insurance web aggregator is the person who collects, maintains and assembles information relating to insurance products offered by different insurance companies. Such information is made available to the consumers seeking insurance services in its online portal. IRDAI (Insurance Regulatory and Development Authority of India) administers the functions of the web aggregator. This concept of Insurance Web Aggregator is governed by the Companies Act and the Insurance Act. Any company desiring to operate as Insurance Web Aggregator need to obtain an Insurance Web Aggregator License from IRDAI.

Insurance Web Aggregators allows buyers with the luxury to compare different insurance products together with their prices and features. However, before commencing these aggregation activities through their websites, it is necessity to obtain Insurance Web Aggregator License. The concept of Insurance Web Aggregators was introduced to spread awareness and education among the people about various insurance products. Another reason behind introducing the concept of Insurance Web Aggregators was to promote transparency, digitalization and highly regulated platform to diminish the earlier practice of charging high commission by the agents to the people who desired to buy any insurance policy. Insurance Web Aggregators provide the luxury to the buyer of insurance policy to compare and make more informed decisions regarding their insurance needs.  

Roles of the Insurance Web Aggregators are to expand and boost the online market for insurance products, improvement and enhancement in the purchase experience of the customers, to promote the insurance sector by making it more transparent and approachable and to assist the customer throughout the process.

Insurance Web Aggregator functions by displaying on their digital platforms about various insurance products. They provide comparison facility between various insurance products in an unbiased manner, on their website. Their function includes transmitting the leads received to the respective insurance company. Selling of products through telemarketing services and soliciting insurance products based on the leads from their website.

Work of insurance web aggregators are quite useful to the buyers and to avoid any fraud, government has strictly prohibited the insurance web aggregators to promote the services offered by any particular insurer. Analysis report are necessary for the insurance web aggregators to sell products. Insurance web aggregators are prohibited from displaying ratings. Ranking or highlighting any products and to even display the pricing of any product. 

Apart from it, Insurance web aggregator have to obtain a license to provide its services. To procure such license, one must fulfil the conditions described. These conditions are that: 

  • The applicant company must be Limited liability partnership (LLP) registered under Limited Liability Partnership Act, 2008 and under the Companies act, 2013.
  • The Memorandum of Association must ensure that it is authorised to undertake the activity of web aggregation of insurance products.
  • A company shall not be engaging in any other business than its main object.
  • The applicant company shall not be appointed as company agent, insurance agent, surveyor and loss agent, micro-insurance agent, insurance marketing firm or any other insurance intermediary. 
  • The applicant shall not be in a referral connection with an insurer.
  • There must be dedicated platform to perform the activities of an insurance web aggregator.
  • The principal officer appointed shall comply with the experience and qualification prescribed, must have obtained the requisite training and must have passed the examination as prescribed by the IRDAI.
  • Key management personnel, the principal officer, promoter, shareholders, director must be according to the criteria as prescribed.
  • The Authorised verifier shall also have the experience and training as per requisite by the IRDAI.
  • The applicant has not been previously rejected for insurance web aggregator by the IRDAI.
  • The insurance web aggregator must perform according to the activities permitted by the IRDAI and shall not violate any restriction.
  • The applicant have not withdrawn any application in the previous financial year.
  • Capital Requirement – a minimum paid-up capital of Rs.25 lakh is requisite and the applicant company can issue equity shares according to the Companies act, 2013 to raise such capital. But so is not the case in Limited Liability Partnership, the contributions made in Limited Liability Partnership must be in cash. Moreover, the aggregate shareholding of foreign investors in Insurance web aggregators shall not be more than 49% of paid-up equity capital.
  • Net Worth Requirements – The net worth of any insurance web aggregator shall never be below 1005 of the minimum capital requirements. It shall be reviewed in every half year and in case of non-compliance, a report shall be filed within 15 days and further a web aggregator will be required to implement restoration measure within a month time. In case the insurance web aggregator fails, it shall cease all its business activities. It shall be certified a net worth certificates after the finalization of the books of accounts from a certified chartered accountant.

These conditions must be duly complied with, to obtain an insurance web aggregator license. Apart from these conditions, an applicant must fulfil the criteria prescribed to proceed further with the registration. Any applicant desiring to perform the functions of telemarketing and outsourcing, the applicant shall mention the same in the application.

Any applicant desiring to obtain an insurance web aggregator license shall file an application to the IRDA in Form A of schedule I. Along with the application, the director shall submit all the requisite documents and a prescribed fee of Rs.10,000/- and applicable taxes. Fee shall be paid in demand draft to the IRDAI. Fee is necessity and any application filed without fee would never process further. Application must contain a detailed five year business plan and its plan-of-action and financial projections. The documents to be filed along with the application area

  • copy of Certificate of Registration (COR), 
  • copies of MOA & AOA if it is a company,
  • PAN card
  • Certified by practising chartered accountant, copy Limited Liability partnership agreement 
  • Details of directors, designated partners and principal officers like copies of their experience and qualification certificates and resumes.
  • A certified declaration of any two designated partners or directors declaring the competency of the principal officer, shareholders, promoters, key managerial personnel or partners that:
  1. Key managerial personnel, directors, shareholders, are major;
  2. They are not of unsound mind;
  3. They have never been involved in economic offence in the past five years;
  4. The directors are not employed neither hold any position in an insurance company;
  5. In the past five years, they have not been guilty in any case of criminal misappropriation, cheating, criminal breach of trust, abetment to commit or forgery in the past five years.
  6. The company’s net worth is not less than INR 25 lakhs.
  • Applicant company’s directors or principal officers are not registered as company agents, insurance agents, micro-insurance agents, insurance brokers, surveyors or loss assessors or any other intermediaries mentioned in IRDAI regulations.
  • Copy of practising chartered accountant’s certificate stating the pattern of shareholding and net worth of the company.
  • Company’s business plans for the next three years.
  • Proposed portal pictures along with proof of domain name registration
  • Address proof of the area where such website would be hosted. That area can be registered office or other offices for operations of the company.
  • Details of the persons who have the authority to post and regulate details about insurance products, guides and comparisons on the portal.
  • Copy of last three financial years’ balance sheets, audited accounts and annual reports.
  • Proposed IT infrastructure and other details of infrastructure available with the applicant
  • Responsibilities and functions of each individual displayed in human resource chart.
  • Authorised verifiers and principal officers training and qualification certificates.
  • Login details by IRDAI Information Technology Department for the verification of the aggregation website, digital or LMS. 

Any application not in compliance with conditions of the IRDAI will be rejected on the face of it and in case of any omission or failure, a period of thirty days is granted to the applicant to rectify the mistakes. The authority may ask the applicant to submit additional clarification or information concerning the documents or details provided by the applicant. A company may be asked to file more than one reply for any query. And the applicant failing to reply within the thirty days granted from the date of communication, will be rejected by the authority and applicant would have to file a fresh application.

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Author
Vinay Singh
Vinay Thakur is Managing Partner in Corpseed. He focused on payments, digital transformation, and financial technology for over 15 years and holds strong expertise on fintech startups, banking innovation, and investors with a keen understanding of the trends and activities of startups, banks, and investors in the space.