Reporting the Insurance Programme to the SEBI Risk Management Committee in India 2026

For most of the last decade, the corporate insurance programme was treated as a procurement line item. A treasury or admin team renewed the policies, the premium hit the budget, and the board saw little beyond a summary number. That arrangement no longer sits comfortably with the way SEBI now expects the Risk Management Committee to work.

Under Regulation 21 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the top 500 listed entities by market capitalisation must constitute a Risk Management Committee with at least three members, of whom a majority (and at least two) are board directors. The committee's remit expressly covers the measures and processes to identify, monitor and mitigate risks, and to review the adequacy of risk mitigation. Insurance is the primary financial mitigant for a large share of a company's physical, liability and business-interruption exposures, so it falls squarely inside that mandate.

Recent tightening has raised the cadence and the discipline. The committee must now meet at least twice in a financial year, with a gap of not more than 210 days between two consecutive meetings, after the SEBI (LODR) (Amendment) Regulations, 2025 dated 27 March 2025 and the further amendment notified on 20 January 2026 substituted the word "year" with "financial year" for committee meeting frequency.

The practical consequence for a Chief Risk Officer or risk manager is that the insurance programme now needs an oversight paper written for directors, not a broker slip written for the market. The rest of this piece sets out how to build that paper.

The insurance-programme paper for the Risk Management Committee is a different document from the Regulation 30 material-event note or the annual BRSR climate section. It is not about disclosing a single claim to the market, and it is not about ESG narrative. It answers one board-level question: is the group's risk-transfer arrangement adequate, priced sensibly, and backed by counterparties who will pay.

A workable structure has five parts, and directors read it fastest when it stays in this order:

1. Programme map: the lines of cover in force (property and business interruption, marine and transit, liability, directors and officers, cyber, engineering and project covers), the insurer on each, and the total sum insured or limit per line.
2. Adequacy assessment: whether limits and sums insured match current values and exposures, with the reinstatement or replacement basis stated.
3. Retention position: deductibles, self-insured layers, and the group's total cost of risk against premium spend.
4. Claims and loss experience: open and closed claims, loss ratios by line, and any emerging pattern.
5. Counterparty security: the financial strength and solvency of the insurers and lead reinsurers carrying the risk.

Keep the body of the paper to a few pages and push the policy schedules into an annexure. Directors are testing whether the risk function understands the exposures, not whether it can reproduce a wording.

Open each section with a one-line judgement, then support it. A statement that property values are 14 percent below current replacement cost and warrant a mid-term revaluation tells the committee more than a table of sums insured ever will.

The sections that follow unpack the four analytical parts, since the programme map is largely descriptive.

Adequacy is the question directors care about most and the one most oversight papers answer worst. The failure mode is a wall of sums insured with no view on whether they are right.

Start with the valuation basis. For property and machinery, state plainly whether the policy is written on reinstatement value or on market or indemnity value, because that single choice can create a large uninsured gap after a total loss. Where the group last conducted an independent valuation matters as much as the number itself. Construction cost inflation and a weaker rupee have pushed replacement costs for imported plant well above book values, so a sum insured set three years ago is very likely inadequate today. Flag the average clause risk in one sentence: under-insurance triggers proportionate settlement, so a plant insured for 70 percent of value collects roughly 70 percent of even a partial loss.

For business interruption, the board needs to see the indemnity period against the realistic recovery time for the worst single site, and the gross-profit basis behind the sum insured. A 12-month indemnity period on an asset that takes 18 months to rebuild is a visible, quantifiable gap.

For liability and specialty lines, adequacy is about limits benchmarked to exposure. Set the D&O limit against the group's market capitalisation and litigation profile, the product liability limit against export markets and turnover, and the cyber limit against a modelled loss scenario rather than a round number.

Frame adequacy as gaps and recommendations, not as a status report. Every line should end in one of three verdicts: adequate, adequate with a caveat, or a gap requiring a board decision.

That verdict column is what lets a director scan the programme in two minutes and know where their attention is needed.

The second analytical section explains how much risk the group deliberately keeps and what that decision costs. This is where a risk function demonstrates that insurance is being bought as a financing decision rather than a reflex.

Set out the retention structure by line: the per-claim deductible, any annual aggregate deductible, and any self-insured or captive layer sitting below the insurers' attachment. Then show the trade. A higher deductible on the property programme cuts premium, and the paper should quantify both sides so the committee can see the exchange. A retention that saves a modest premium but exposes the group to a large working-layer loss is a decision the RMC should take consciously, not one that arrives by default at renewal.

The total cost of risk figure ties it together: premium paid, plus retained losses, plus the internal cost of running the risk function and any captive. Presenting insurance as total cost of risk rather than premium alone stops the board from treating a premium reduction as an automatic win when it has quietly transferred exposure back onto the balance sheet. For groups with multiple entities, note how that cost is allocated, since the cost-of-risk allocation across group entities affects which subsidiary board carries which line. A deductible the operating company cannot fund from cash flow is not a retention, it is an unfunded liability, so state the largest plausible retained loss in a bad year rather than the expected one.

Directors respond well to a simple sensitivity line: at the current retention, a normal loss year costs X, and a one-in-ten bad year costs Y. That single comparison converts an abstract deductible into a balance-sheet question the board is equipped to answer.

The claims section is where the insurance paper earns its place as a risk document rather than an insurance status update. Directors are not interested in every small claim. They want the pattern and its implications for next year's cover and price.

Present loss ratios by line over a rolling three to five year window, so the committee sees direction rather than a single year that could be an outlier. A property loss ratio climbing toward and past 100 percent tells the board to expect a hard renewal, tighter terms, or a higher retention imposed by the market, and it is far better for the RMC to hear that in advance than at the renewal meeting. For liability lines, count and age of open claims matters more than paid figures, because long-tail exposures under directors and officers liability or product liability can sit open for years before a reserve moves.

Use the section to surface emerging exposures the programme may not yet cover. A new export market changes product liability exposure. A cyber incident elsewhere in the sector is a prompt to test the group's own cyber insurance limit against a modelled ransomware and business-interruption loss. A new plant under construction brings erection and contractors' all-risks exposures that should appear before, not after, the asset is capitalised.

Tie the claims narrative to the disclosure obligations the same board carries. A large claim or a denied claim can itself become a material event under SEBI LODR Regulation 30, so the RMC and the disclosure committee should be working from the same claims picture rather than two disconnected views. The claims section, done well, is an early-warning instrument, and that is precisely the function Regulation 21 asks the committee to perform.

A policy is only as good as the balance sheet standing behind it, and this is the section most insurance papers omit entirely. The Risk Management Committee is well placed to ask the question a procurement team rarely does: if the worst loss happens, will the insurer pay, and can it.

For every material line, state the lead insurer and its financial standing. All Indian general insurers are registered with and supervised by the IRDAI and must maintain a solvency margin of at least 150 percent, so the paper can note where each carrier sits against that floor rather than treating solvency as a binary pass. Where cover is placed with or fronted for an international insurer, or where a domestic insurer relies heavily on treaty reinsurance, the board should see who the ultimate risk carrier is. A local policy fronted onto an offshore reinsurer transfers counterparty risk to that reinsurer's balance sheet, and for large limits that concentration deserves a line in the paper.

Concentration is the second counterparty question. If a single insurer carries the property, engineering and business-interruption cover for the group's largest sites, the RMC is looking at correlated counterparty exposure, and a co-insurance or layered placement may be the more prudent structure.

The committee is not asked to underwrite the insurers. It is asked to confirm that someone has looked, that the security is documented, and that concentration has been considered deliberately.

The final piece is process discipline, because Regulation 21 is enforced through what the committee records, not merely what it discusses. With a minimum of two meetings a financial year and a 210-day gap ceiling, the insurance programme should feature on the agenda at least twice: a full renewal-strategy paper ahead of the main renewal, and a shorter between-cycle update covering claims movement, mid-term changes and any new exposure.

Write the minutes so an inspection or an auditor can reconstruct the decision. When the committee accepts a coverage gap, a higher retention, or a particular insurer, the minute should show the recommendation, the alternatives considered, and the reason for the choice. That evidence trail protects the directors personally if a decision is later questioned, and it is the difference between a committee that governs risk and one that merely notes it. Keep the supporting papers, the broker's placement report and the valuation basis in the committee pack so the file is complete. This is the same governance logic that sits behind a claims governance committee and behind broader board risk reporting on insurance.

Most of the delay in preparing these papers goes into reconstructing what each policy actually covers: the exclusions, the conditions, the sub-limits and the wording differences between one insurer's form and another's. Sarvada makes that step searchable. Risk teams and their brokers can compare insurer policy wordings clause by clause, confirm how a limit or exclusion actually reads before it goes into a board paper, and cite the exact term rather than a paraphrase. If you are building or sharpening the insurance section of your Risk Management Committee pack, request access to see how quickly the wordings intelligence turns a stack of policies into a defensible adequacy view.