Reconciling Your Commission Statement: What POSPs Should Check Line by Line

A POSP is remunerated by the entity that engages them, insurer or intermediary, under the contract of engagement. You are not an independent commission earner standing opposite the insurer. This is not a technicality. It is the defining feature of the channel, and it flows from the same design that ties a POSP to one insurer or intermediary at a time.

Where an insurer engages you directly, the chain is short: the insurer engages you, the insurer pays you, and your statement comes from the insurer.

Where an intermediary engages you (a broker, corporate agent or web aggregator), the chain has a link in the middle. As a general matter of market structure, commission on the policy is payable by the insurer to the intermediary, and the intermediary then remunerates you under your contract. This is how the channel is generally understood to operate rather than something to read out of a regulation, but the commercial consequence is exact: the rate the insurer pays your principal and the rate your principal pays you are two different numbers, and only the second one is yours. Your contract governs the second number. The first is not your entitlement and, in most arrangements, not your business.

On passing the examination, the engaging insurer or intermediary must issue your certificate and appointment letter within 15 days and allocate you a unique POS Code. The master circular is explicit about what that code then does: every proposal must carry the POS Code, and the insurer is responsible for recording it.

Which produces the most common and most preventable gap on any POSP statement: the policy exists, the client is real, the premium was paid, and your code is not on it. The proposal went in under a different code, a default code, or nothing at all. Someone at the counter keyed it wrong, the client completed the purchase through a link that did not carry your attribution, or the proposal was reworked and the code did not survive.

A missing-code policy does not appear on your statement as a wrong number. It does not appear at all. This is why reconciliation cannot be done by reading the statement. The statement only knows about policies it already believes are yours. What you need to find lives in the gap between your record and the statement's record, and you cannot see a gap from one side of it.

So the rule that precedes all others: capture the policy number and confirm your code is on it at the point of sale, while the client is still in front of you and the proposal is still open. Recovering attribution a quarter later means asking your principal to ask an insurer to restate a policy record, which is a favour, not a process.

Your side is a record, made at the point of sale, of every policy you placed. It does not need software. It needs to exist, to be complete, and to be captured on the day rather than reconstructed at month end from chat history. The fields that do real work:

• Policy number, exactly as issued. This is the join key. Client names do not join; they get spelled three ways.
• Date of issue and date of proposal. The gap between them explains most timing disputes.
• Insurer and product.
• Premium, and specifically what it is composed of, because the base your remuneration is calculated on is rarely the number the client paid.
• Confirmation that your POS Code went on the proposal.
• Expected payout, computed from your engagement schedule at the moment of sale.

That last field is the one advisors skip, and skipping it dissolves the exercise. If you do not write down what you expected before you see what you were paid, whatever arrives becomes the expectation. You will read the statement, the number will look plausible, and you will move on. Every unnoticed short-payment in this channel lives in that moment.

Premium composition deserves care. Remuneration is generally calculated on a base that strips out components that do not carry it. On a motor policy the client pays own-damage premium, third-party premium, add-on premium and tax, and these do not all carry remuneration at the same rate, or at all. If your schedule quotes a percentage, the question is a percentage of what. Ask your principal to state the base in writing, per product. An advisor who assumes their rate applies to the amount the client transferred will conclude they are short-paid on every motor policy they ever sold, will be wrong, and will burn their credibility making the complaint.

1. Join on policy number. Match every line on the statement to a row in your record. Two exception lists fall out, and both matter.
2. Work the in-my-book-not-on-the-statement list first. This is where the money is. Each row is either an attribution failure (your code did not make it onto the proposal), a timing gap (the policy issued after the statement's cut-off and will appear next month), or a policy that did not actually incept (the client did not pay, or the proposal was declined). Establish which before you raise anything, because the second category resolves itself in thirty days and raising it makes you look like you cannot read a cut-off date.
3. Work the on-the-statement-not-in-my-book list. Do not delete these and do not quietly bank them. A line you do not recognise is either a policy you forgot to record, a renewal you did not know had happened, or somebody else's business credited to your code. The first two are useful information. The third is a problem you want to raise yourself rather than have discovered later, and the fastest way to lose your principal's trust is to be the advisor who queries every short-payment and never mentions the overpayment.
4. Recompute the matched lines. For each, recalculate the payout from your engagement schedule against the correct premium base and compare it to what was credited. Do this on the full population if the book is small enough, which for most solo advisors it is.
5. Age everything unresolved. An open item at 90 days is materially harder to recover than the same item at 30, because the people involved have moved on and the accounting period has closed.

The output is not a list of grievances. It is one message to your principal, once a month, listing specific policy numbers with specific expected amounts and the reason for each. That message gets answered. Fifteen separate messages saying "I think I am short" do not.

Missing entries. The largest by value. The policy is real and your code is not on it. Diagnosis: policy number exists, client confirms cover, no statement line, no reversal. This is the family worth building your point-of-sale discipline around, because it is the only one invisible from the statement.

Cancellations and reversals. The client cancelled, the insurer refunded premium, your payout reverses. Legitimate, and you should expect it. What you check is that it reversed once. A reversal taken on two consecutive statements is an ordinary systems error and entirely your job to notice, because nobody else is looking at your account. Also check that a reversal is not sitting against a policy that was never cancelled, which happens when policy numbers are keyed loosely.

Short-period and mid-term adjustments. A policy issued for less than a full term, or a refund on a mid-term cancellation, produces a proportionate premium and a proportionate payout. The arithmetic is usually right. What is often wrong is that the adjustment lands on the wrong policy, or that a premium-bearing endorsement generated additional premium with no corresponding payout.

Timing gaps. The largest source of wasted arguments. Your statement has a cut-off; a policy issued on the 29th may fall into next month's run. Check the previous statement first, and wait one cycle on anything issued within a week of the cut-off. Track open items across months rather than resetting each month, or you will report the same policy missing twice and then find it was paid the first time.

Rate and base differences. The credited amount is right on the rate but wrong on the base, or the reverse. There is no POSP-specific commission cap in force; POSP remuneration sits inside the insurer's board-approved commission policy under the IRDAI (Payment of Commission) Regulations, 2023, itself bounded by the aggregate ceilings in the IRDAI (Expenses of Management, including Commission, of Insurers) Regulations, 2024, roughly 30 percent of gross written premium for general insurers and 35 percent for standalone health insurers. Because rates now move with insurer board decisions rather than a fixed regulatory table, terms can change mid-year. Your protection is a written record of the effective date of every change your principal communicates. An advisor working from a rate they were told about eighteen months ago cannot tell a rate cut from an error.

Tax is deducted at source on your payout. Your principal deducts it and deposits it against your PAN, and the gross figure on your statement is what you are taxed on, not the net figure that arrived. The reconciliation that actually protects you is between your statements for the year and your Form 26AS and Annual Information Statement. If the credits your principal reports do not match the payouts you recorded, you have found either a statement error or a deposit failure, and both are far easier to fix inside the financial year than after you have filed.

On the indirect tax treatment of your remuneration, get the answer from your principal in writing rather than from another advisor. The treatment depends on the structure of your engagement and on who is accounting for what, and the honest position for most solo advisors is that this is a question for your principal and your accountant, not one to settle from a WhatsApp group. What you should insist on is that your statement shows the gross payout, each deduction, and the net, separately and labelled. A statement that shows only a net figure is not a statement. It is a payment advice, and you cannot reconcile against it.

The practical habit: file every monthly statement as it arrives, in one place, named by month. Twelve files. At year end you have a book that reconciles to your bank and to your tax record, and the exercise takes an evening. Advisors who skip this reconstruct the year in June from bank entries and never do find the two policies that went missing in October.

As of the date of this post, IRDAI is preparing an overhaul of insurance commission rules aimed at curbing mis-selling. The consultation paper has not been published. Reporting on 3 July 2026 records Chairperson Ajay Seth indicating a paper expected by end-July 2026, and reporting through 9 July 2026 sets out four ideas said to be on the table. All four are proposals and none is in force: staggered or trail commissions spread over the policy life rather than concentrated upfront; effort-based remuneration under which advisors giving personalised advice, helping with documentation and supporting claims could earn more than distributors such as banks selling insurance as an add-on; product-wise caps differentiated by complexity and tenure; and tighter remuneration disclosure. The reporting also notes that distributors can currently earn up to roughly 40 percent of premium on some life and health products, much of it paid at the time of sale. That is an observed market level, not a regulatory cap, and it is a market-wide figure, not your rate.

The advisor who keeps a point-of-sale record with an expected payout against every policy number is not preparing for a regulation that may never arrive. They are doing the thing that pays this month, in a way that happens to survive whatever the paper says. The reverse is not true: an advisor with no record has nothing to reconcile against under any regime, and no way to notice that the policy they sold in October was never credited at all.