Draft IRDAI (Insurance Intermediaries) (Amendment) Regulations 2026: The Disclosure Regime Brokers Must Now Build For

In June 2026 IRDAI published the draft IRDAI (Insurance Intermediaries) (Amendment) Regulations, 2026 for public comment. The draft is exactly that: a draft. Nothing in it is in force, and the final text may differ on thresholds, timelines, and format. But the direction is unambiguous, and broking firms that wait for notification before acting will find the first compliance cycle uncomfortable.

The draft applies across the intermediary spectrum: insurance brokers, corporate agents, insurance marketing firms, and web aggregators. For brokers, it proposes three connected obligations. First, financial statements must carry a separate schedule disclosing revenues from insurance intermediation and other income or receipts from insurers, splitting what has often sat inside a single revenue line. Second, intermediaries must submit audited financial statements, together with the auditor's report, to IRDAI by 30 September each year. Third, those audited statements must be published on the intermediary's own website, moving broker financials from a private regulatory filing to a public document that clients, insurers, and competitors can read.

The draft also proposes stricter disclosure requirements for intermediaries earning more than INR 10 crore in commissions, creating a two-tier regime in which larger firms carry a heavier disclosure load.

The context matters. Since the IRDAI (Payment of Commission) Regulations, 2023 removed product-wise commission caps, insurers have paid commission under board-approved policies constrained only by the overall expenses-of-management ceiling in the IRDAI (Expenses of Management, including Commission, of Insurers) Regulations, 2024. Flexible commissions with limited intermediary-side transparency created an information gap. This draft is the regulator closing that gap from the intermediary side: if commission structures are free, the money flows must at least be visible.

The core of the draft is the schedule that separates revenue from insurance intermediation from other income or receipts from insurers. That distinction sounds simple. In most broking P&Ls it is not.

Intermediation revenue is the brokerage and commission earned on placements: base commission, and any variable or reward components tied to placement activity. Other receipts from insurers cover everything else that flows from carrier to broker: infrastructure or technology support payments, marketing and co-branding contributions, reimbursements for events or training, fees for surveys or data services, and payments routed to group entities that ultimately trace back to an insurer relationship.

Why does IRDAI want the split? Because payments outside the commission line have been the classic route around remuneration discipline. A broker showing a modest commission yield while receiving material marketing support from the same insurer presents a different economic picture once the schedule forces both numbers into daylight. The 2024 EOM framework already requires insurers to count these payments inside their 30 percent (general) and 35 percent (standalone health) expense ceilings. The draft mirrors that on the receiving side, letting the regulator reconcile what insurers report paying against what intermediaries report receiving.

For a broking CFO, the practical questions are immediate:

• Which existing revenue GL codes map to intermediation revenue, and which to other receipts?
• Are there receipts booked in group companies (a technology affiliate, a marketing entity) that a consolidated reading would attribute to the insurer relationship?
• Do reward and recognition receipts sit in the right bucket, and can each one be traced to a specific insurer agreement?
• Can the firm produce insurer-wise detail if the final rules or a supervisory query demand it?

A firm that cannot answer these from its trial balance today has a chart-of-accounts project ahead of it, one that takes a full year to run cleanly because it changes how transactions are coded at entry.

The proposed filing obligation, audited financial statements with the auditor's report submitted to IRDAI by 30 September each year, looks routine until you place it against how broking firms actually run their audit calendars.

Many mid-tier brokers complete statutory audits close to the Companies Act outer limits, with accounts adopted at an AGM held near the 30 September deadline for most companies. Under the draft, the IRDAI submission lands on the same date. A firm that historically signed its audit in late September has zero slack: any audit qualification, any dispute over revenue recognition, any delay in insurer balance confirmations pushes the firm into a regulatory default, not just a corporate-calendar squeeze.

The auditor's report requirement raises the stakes on issues auditors have often handled with materiality judgment:

1. Revenue recognition on commission: whether brokerage is recognised on policy issuance, premium realisation, or receipt, and whether that treatment is consistent across insurers and lines. Under the accounting standards applicable to the firm, recognition should follow the transfer of the placement service, but practice varies, and a public filing invites scrutiny of the chosen policy.
2. Unreconciled insurer balances: commission receivable positions that differ from insurer statements. An auditor comfortable with a netted judgment in a private filing may write differently when the report goes to IRDAI and the firm's website.
3. Related-party receipts: payments from insurers to group entities, which the schedule structure is designed to surface.

The realistic response is to pull the audit timetable forward. Firms should target audit sign-off by 31 July, leaving August for board adoption and September as buffer. That in turn means closing the books faster: insurer balance confirmations requested in April, commission reconciliations current through year-end rather than rebuilt after it, and TDS credits under Section 194D matched to booked revenue before the auditor arrives, not during the audit.

The proposal that audited financial statements be published on the intermediary's website changes the audience for broker accounts more than any other element of the draft.

Today a broker's financials are visible to the regulator, its bankers, and anyone willing to pull filings from the MCA portal. Website publication removes even that small friction. Three groups will read them.

Clients and prospects. Large commercial insurance buyers already ask brokers about remuneration on their placements. A public P&L showing total commission income, and under the schedule, other receipts from insurers, gives procurement teams a new negotiating document. A corporate client comparing two brokers will see which one earns heavily from insurer-side receipts and draw its own conclusions about alignment.

Insurers. Carriers will see the full revenue picture of every broker on their panel, including what competitors pay. Expect that visibility to compress outlier arrangements toward the middle.

Competitors and press. Broking league tables in India have been built on estimates. Public audited statements end that.

None of this is an argument against the proposal; it is the point of the proposal. But principal officers should prepare the firm's narrative before the numbers go public. A broker whose accounts show, say, 30 percent of revenue as non-intermediation receipts from insurers should be able to explain what services those receipts paid for, with agreements to match.

The draft proposes stricter disclosures for intermediaries earning more than INR 10 crore in commissions. The final contours of the stricter tier will only be known on notification, but the threshold itself already tells firms which side of the line they sit on and what to do about it.

At roughly a 12 to 15 percent blended commercial-lines yield, INR 10 crore of commission corresponds to premium handled in the region of INR 65 to 85 crore. That captures every national broker, essentially all PE-backed and platform brokers, and a substantial slice of the mid-tier. It excludes most small regional firms, which is consistent with proportionate regulation: the compliance cost of enhanced disclosure is fixed in nature, and spreading it over a small revenue base would be punitive.

Firms near the line need to think about measurement. Is the threshold tested on commission income alone, or on total receipts from insurers including the other-income bucket? Is it tested on the standalone entity or across group entities? The draft consultation is the moment to seek that clarity; ambiguity discovered after notification is resolved by supervisory interpretation, rarely in the intermediary's favour.

Firms clearly above the line should assume the stricter tier will involve some combination of insurer-wise or segment-wise revenue detail, disclosure of remuneration policies, and possibly reconciliation-style statements linking receipts to underlying placements. Building the data spine for that now, insurer-wise, line-wise revenue that ties to the general ledger, is cheaper than retrofitting it under a filing deadline.

Firms just below the line should note that growth carries them across it: a broker at INR 8 crore of commission growing 20 percent annually crosses within two years, so design the finance function for the stricter tier from the start.

Meeting the draft's requirements is not a compliance memo; it is a finance transformation with five workstreams.

1. Chart of accounts and coding discipline. Create distinct GL structures for intermediation revenue (split by base commission and variable or reward components, and ideally by insurer and line) and for other receipts from insurers (split by nature: infrastructure, marketing, reimbursements, service fees). Every inward payment from an insurer must be coded at entry against a specific agreement. Retro-classification at year-end is where errors and auditor disputes are born.
2. Reconciliation cadence. Move from annual or quarterly commission reconciliation to monthly. Each insurer statement should be matched to booked revenue within 30 days, with ageing on unmatched items reviewed by the CFO. Firms already running the reconciliation discipline that GST and Section 194D TDS matching demands have a head start; the draft effectively makes that discipline a regulatory expectation rather than good hygiene.
3. Audit readiness. Appoint or re-confirm auditors early, agree the revenue recognition policy in writing before year-end, and hand the auditor a reconciliation pack rather than a shoebox. Target sign-off by 31 July to protect the proposed 30 September filing date.
4. Website and publication workflow. Decide where on the site the statements will live, who approves the upload, and how prior years are archived. Trivial technically, but it needs an owner, because a stale publication is an easily detected breach.
5. Governance. Put the draft on the audit committee agenda now. The committee should approve the schedule mapping, the recognition policy, and the disclosure narrative, and should see a mock schedule built on current-year numbers at least two quarters before the first real filing.

For a mid-tier broker the incremental cost is bounded: typically one additional finance hire or a fractional controller, INR 15 to 40 lakh of one-time systems and mapping work, and a modest rise in audit fees. Set against a public audit qualification or a late filing on the regulator's record, it is an easy investment case.

The draft does not stand alone. The Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025, in force from 5 February 2026, restored IRDAI's statutory power to cap distributor commissions and strengthened its ability to prescribe the manner of payment and disclosure of remuneration. In July 2026, reporting indicated IRDAI is preparing a consultation on restructuring commissions themselves, including staggered trail payouts and effort-based remuneration, with tighter remuneration disclosure explicitly on the list.

Read together, the sequence is coherent. The 2023 commission regulations freed pricing. The 2024 EOM framework capped the aggregate envelope on the insurer side. The 2025 Act restored the legal power to intervene on rates. The 2026 intermediary draft creates the data: standardised, audited, public numbers on what intermediaries actually earn and from whom. Whatever IRDAI ultimately decides on commission structure, it will decide it with intermediary revenue fully visible.

The strategic implication: disclosed numbers will inform future rule-making. If the published schedules across the industry show heavy other-income receipts relative to commission, expect rules targeting those flows. If they show healthy intermediation margins, expect that data cited in any future cap discussion. Individual firms cannot control the industry picture, but they can control whether their own disclosures are accurate, explicable, and supported by agreements.

The immediate calendar: submit consultation comments, directly or through the Insurance Brokers Association of India, on threshold measurement, the 30 September date's fit with Companies Act timelines, and first-year transition. Then build as if the substance will survive consultation, because on current direction, it will.