Building the Intermediary Disclosure Pack: Data Your Firm Should Assemble Before IRDAI's Norms Are Finalised

The IRDAI (Insurance Intermediaries) (Amendment) Regulations exposure draft went up on 19 June 2026, and the comment window closed on 10 July 2026. Nothing about it is final. The version that eventually notifies may raise the threshold, change the filing date, or drop a disclosure item entirely, and a firm that reorganised its accounting around the draft would have moved too early.

The data assembly is a different matter. Every disclosure the draft contemplates rests on records the firm should be able to produce regardless of whether the rule notifies: what it earned in commission by insurer, what it transacted with parties connected to its owners and directors, what profit it made, and what it paid out to shareholders. A firm that cannot assemble those four things today has a data problem the draft merely exposed. The disclosure norm, if it lands, is a deadline. The underlying legibility is worth having either way.

So the work to start now is not compliance with a proposal. It is a readiness exercise: map what the draft would ask for against what the firm can actually produce, find the gaps while there is no clock running, and close them at project pace rather than under a filing deadline. This post is that mapping. It assumes the substance of the draft is understood elsewhere, in the companion piece on what the amendment regulations propose, and concerns itself only with the data-assembly workstream behind the four disclosure heads.

The draft draws its line at intermediaries earning over Rs 10 crore in commission in a year. The first workstream is therefore not a disclosure at all. It is establishing, defensibly, which side of that line the firm sits on, because the answer decides whether any of the rest applies.

That sounds trivial and is not, for two reasons.

1. Commission earned is not one number in most broking systems. Gross brokerage, net of reversals, net of co-broking shares paid away, inclusive or exclusive of reward and variable components, and inclusive or exclusive of reinsurance broking income: these produce different totals, and a firm sitting near Rs 10 crore can be inside or outside the threshold depending on which definition the final rule adopts. Until the definition is fixed, compute the figure on every plausible basis and know the range.
2. The figure must reconcile to the audited accounts. A commission total pulled from the broking system that does not tie to the revenue line in the statutory financials is a disclosure that contradicts itself before anyone reads it. The reconciliation between the placement system and the audited profit and loss account is the same reconciliation the firm needs for its ageing and its returns, worked in the piece on commission accounting under the EOM regime.

A firm comfortably below the threshold on every basis can note the position and stop. A firm within a crore of the line on any basis should treat itself as in scope for planning, because a growing book crosses the line without anyone deciding to.

Related-party disclosure is where readiness projects run over, because the population of related parties is larger than the firm thinks and lives in registers nobody consults day to day.

Start from the definitions that already bind the company. Section 188 of the Companies Act, 2013 and Ind AS 24 (or Accounting Standard 18 for firms not on Ind AS) already require a related-party register: the holding company, subsidiaries and associates, key managerial personnel and their relatives, and entities controlled or significantly influenced by any of them. A broking firm's statutory auditor maintains a version of this. It is the starting inventory, not the finished one.

Then extend it to the arrangements a broker specifically runs with connected parties, which is where the disclosure interest sits:

• Co-broking with a related broker. A placement split with an entity under common ownership is a related-party transaction whether or not it was ever labelled one.
• Reinsurance broking routed to a group reinsurance broker. Income or splits flowing to a connected reinsurance intermediary belong in the map.
• Outsourcing to group entities. Technology, back-office, or lead-generation services bought from a company owned by the same promoters, priced at whatever the group decided.
• Referral and sourcing arrangements with connected distributors, which also carry their own regulatory constraints beyond disclosure.
• Management fees, royalties and brand charges paid up to a parent, common in foreign-owned structures.

For each, the disclosure-ready record is the counterparty, the relationship basis, the nature of the transaction, the value in the year, and the pricing basis. The uncomfortable finding on most first passes is that several of these were transacted on terms nobody documented, which is exactly the exposure the disclosure regime is designed to surface. Better to find it now, at desk pace, than in a published schedule.

The draft's core disclosure is commission earned, and the honest version of it is commission earned per insurer, because an aggregate figure tells a supervisor nothing about concentration or about whether a single carrier's payments are out of line with the business placed.

The assembly question is whether the broking system can produce this cleanly, and for many firms the answer is not yet. The recurring obstacles:

• Insurer master hygiene. A system carrying one insurer under several spellings and legacy codes cannot total that insurer's commission without a clean-up first. The same free-text contamination that breaks a data migration breaks this report.
• Gross versus realised. Commission booked at placement and commission actually received differ by the receivable, and the disclosure should be explicit about which it reports. The gap is the subject of the receivable-ageing discipline, and a firm reporting booked commission while carrying a large unreconciled tail is disclosing a number it has not collected.
• Reconciliation to the statement. Commission the system believes it earned and commission the insurer's statement confirms are two figures, and only their reconciled intersection is safe to publish. Firms that run automated statement reconciliation already hold this; firms that reconcile quarterly by spreadsheet will find the disclosure forces the monthly discipline they had deferred.

The deliverable to build now is a repeatable query, not a one-off extract: commission by insurer, by line, gross and realised, reconciled to the audited revenue, produced on demand. If it takes a fortnight of manual work each time, it is not disclosure-ready, whatever the final rule says.

The draft's interest in profit and in dividend repatriated is pointed, and it reads against the ownership structure of the modern broking market. Insurance intermediaries have been open to 100 percent foreign direct investment since the 2019-20 liberalisation, and a meaningful share of large broking revenue now sits in foreign-owned firms whose profits flow to overseas shareholders. A regulator asking what was earned and what was sent out is asking whether distribution income is being extracted rather than reinvested.

The assembly is straightforward if the records exist and awkward if they do not:

1. Profit, cleanly stated. The audited profit after tax, reconciled to the same commission revenue disclosed above, so the two disclosures agree.
2. Dividends declared and paid in the year, with the resolution dates, the amounts, and the shareholders they went to.
3. The repatriation trail for foreign shareholders. Dividend paid to a non-resident shareholder is a current-account transaction and is permissible, but it sits on top of the original foreign investment reported to the Reserve Bank in Form FC-GPR, and tax is deducted at source on the distribution. A firm that cannot connect its dividend outflow to its original FC-GPR filing has a FEMA housekeeping gap independent of anything IRDAI does.

None of this requires new accounting. It requires that the company secretary's dividend records, the RBI filings, and the audited accounts be pulled into one place and made to agree, which is a morning's work if the underlying filings were done properly and a project if they were not.

The draft would require the disclosures not only to be filed with IRDAI but to be published on the intermediary's own website, and the second channel is the one firms underestimate. Filing a schedule to a regulator is a controlled act. Publishing the same figures to the open internet, where a competitor, a client, or a journalist can read them, is a different exposure and needs a different workflow.

The readiness work here is procedural rather than analytical:

• Decide who signs off before anything is published. A public financial disclosure should carry the same internal approval as a regulatory filing, which means the principal officer and the finance head at minimum, and the board where the firm's governance requires it.
• Fix the format and the location once. A stable, dated page under a predictable path, so that this year's disclosure and next year's sit in a comparable place and a reader can find the series. Ad hoc PDFs uploaded to wherever the marketing team had space are how inconsistent disclosures happen.
• Reconcile the public number to the filed number before both go out. The single worst outcome is a website figure that does not match the figure filed with IRDAI, because it invites the question of which is wrong, and there is no good answer.
• Version and retain. Keep every published version, dated, so that a later query about what the firm disclosed in a given year can be answered from a record rather than from memory.

The workflow can be built and rehearsed now against draft figures, so that if the rule notifies the firm is executing a tested process rather than inventing one under a deadline.

The point of starting before the rule is final is to convert an eventual deadline into a list of gaps the firm closes at its own pace. The assessment is a single pass against four questions, each answered honestly rather than optimistically.

1. Threshold. On every plausible definition of commission, is the firm above or below Rs 10 crore, and does the figure reconcile to the audited accounts? Output: a scope decision with a documented basis.
2. Related parties. Does a complete, current related-party map exist, extending past the statutory register to co-broking, group outsourcing and management charges, with a value and a pricing basis against each? Output: a map, and a list of arrangements transacted on undocumented terms.
3. Commission by insurer. Can the system produce commission per insurer, gross and realised, reconciled to revenue, on demand? Output: a query, or a data-hygiene backlog if it cannot.
4. Profit, dividend and repatriation. Do the audited profit, the dividend records and the FEMA filings agree and connect? Output: a reconciled set, or a housekeeping backlog.

Each gap gets an owner and a target date, and the whole thing gets revisited when the final regulation notifies, because the notified version will move some of the goalposts. The firms that will file calmly are not the ones that guessed the rule correctly. They are the ones that used the consultation period to make their own numbers legible to themselves, on the reasonable assumption that a regulator who has now asked for this data once will ask for it again in some form. The consultation closed on 10 July 2026 with the shape of the final rule still open. The data assembly does not need the rule to be settled to be worth doing.