IRDAI Use-and-File Product Regime in 2026: What Brokers Need to Know

Indian general insurance products historically moved to market through the File-and-Use regime, under which insurers filed product specifications with IRDAI and waited for explicit clearance before launch. The pre-clearance step protected policyholders against opaque or unfair wordings but added months of lag between insurer product design and market availability. As Indian commercial lines de-tariffed across the 2007 to 2017 cycle and insurer product strategies diverged, the lag became a binding constraint on innovation.

IRDAI issued the IRDAI (Product Approval and Modification) Regulations, 2017 as the first material shift, allowing certain product categories to launch under shorter timelines. The decisive move came with the IRDAI Circular dated 1 June 2022 on Use-and-File, which extended the regime across most general insurance lines including commercial fire, engineering, marine, liability, and miscellaneous. Under Use-and-File, insurers can launch products immediately after internal product-committee approval and file the documentation with IRDAI within specified timelines for post-launch review.

The shift has compressed product time-to-market from typical 6 to 9 month cycles under File-and-Use to 4 to 12 week cycles under Use-and-File for most commercial products. Insurers have responded with materially expanded product catalogues, with each of the top four private insurers (ICICI Lombard, HDFC ERGO, Bajaj Allianz, Tata AIG) launching between 40 and 75 new commercial product variants across 2023 to 2025. The pace continued into 2026 with new variants targeting climate-physical-risk parametric covers, AI-services professional indemnity, and modular cyber wordings.

For brokers, the shift has changed three things at once. First, the comparison memo work has become harder because more products are in market and the variants differ in meaningful ways on definitions, exclusions, sub-limits, and trigger language. Second, the broker advisory role on product selection has become more valuable because clients cannot reasonably keep current with the product catalogue themselves. Third, the documentation discipline around recommendations has tightened because IRDAI inspection now probes whether brokers actually compared current-generation products or recycled older comparison memos.

The Use-and-File scope across 2023 to 2026 has progressively expanded to cover almost all commercial general insurance lines. The exclusions are now narrower than the inclusions.

Products under Use-and-File for commercial brokers include:

• Fire and allied perils including Standard Fire and Special Perils (SFSP), Industrial All Risks (IAR), Standard Fire excluding STFI, and Bharat Sookshma Udyam Suraksha variants.
• Engineering insurance covering Contractors All Risks (CAR), Erection All Risks (EAR), Contractors Plant and Machinery (CPM), Machinery Breakdown (MB), Boiler and Pressure Plant, Electronic Equipment Insurance (EEI), and Advance Loss of Profits (ALOP) variants.
• Marine insurance including cargo (Institute Cargo Clauses A, B, C variants), inland transit, marine hull and machinery, and stock throughput.
• Liability insurance spanning Commercial General Liability, Public Liability (Industrial and Non-Industrial), Product Liability, Professional Indemnity, Directors and Officers Liability, Workmen's Compensation extensions, Employers' Liability, and Errors and Omissions variants.
• Miscellaneous commercial including Burglary, Money Insurance, Fidelity Guarantee, Crime Insurance, Group Personal Accident, Group Health Insurance, and Event Cancellation.
• Specialty and emerging products covering Cyber Liability, Reputational Harm, Trade Credit (with ECGC co-existing), Surety Bonds (under the 2022 Surety Insurance Contracts Guidelines), Climate Parametric Covers, and Travel and Business Travel Accident.

Products still under File-and-Use (requiring IRDAI prior approval) include certain microinsurance products requiring conformance with specific IRDAI microinsurance regulations, products with material consumer-protection sensitivities (some health and retail variants), and products graduating from the regulatory sandbox where IRDAI requires monitored launch. Each of these categories has a specific filing pathway that brokers should verify before advising clients on product availability timelines.

Every product launched under Use-and-File is assigned a Unique Identification Number (UIN) that follows IRDAI's structured numbering scheme. The UIN is the key reference for product identification across IRDAI systems, insurer filings, broker comparison work, and policy issuance. Brokers comparing products across insurers should record UINs in the comparison memo as the unambiguous product identifier.

The UIN structure follows the pattern of insurer code, product class code, sequential product number, and revision indicator. For example, a fire product from a specific insurer might carry a UIN like IRDAN123P00012V03 where IRDAN123 identifies the insurer, P00012 is the sequential product number, and V03 is the third revision of that product. Brokers tracking product evolution over time should monitor revision numbers because revised products may have material wording differences from prior revisions.

Insurers filing a Use-and-File product must submit:

1. Product approval evidence from the insurer's product management committee, with documented assessment of pricing adequacy, wording conformance, target market, and consumer protection.
2. Detailed wording document in the IRDAI prescribed format with definitions, scope, exclusions, conditions, claims procedure, dispute resolution, and policyholder rights.
3. Rate filing including base rates, loading factors, discount factors, and rating algorithms with actuarial certification.
4. Risk model documentation including loss frequency assumptions, severity assumptions, reinsurance support, and capital allocation.
5. Underwriting and claims manual sufficient to demonstrate operational readiness.
6. Consumer protection compliance including suitability assessment framework, disclosure documents, and grievance handling.

Filing is typically required within 15 to 30 days of product launch depending on product class. Late filing attracts regulatory observations and, in egregious cases, product withdrawal directions. Insurers maintain dedicated regulatory affairs teams to manage filing discipline, and brokers should verify filing completeness when comparing variants for advisory purposes.

Post-launch review by IRDAI

IRDAI exercises a structured post-launch review across three layers. The filing examination within the first quarter after filing checks documentation completeness and conformance with the prescribed format. The performance review at 12 and 24 months checks loss ratios, complaint volumes, and any divergence between filed assumptions and actual experience. The market conduct review is triggered by complaints, broker reports, surveyor feedback, or insurer self-reporting and can lead to specific product withdrawal directions. IRDAI has used product withdrawal selectively across 2023 to 2025 against products with material consumer protection defects, with 17 commercial products withdrawn or materially modified through 2024 to 2025.

Use-and-File has reshaped broker advisory work in four ways that compound over the renewal cycle.

Faster product launches require continuous monitoring

Under File-and-Use, brokers could refresh their product knowledge once or twice a year and remain current. Under Use-and-File, with product launches landing across the catalogue continuously, the refresh cadence has compressed to quarterly at minimum and monthly for active commercial books. Brokers without a structured product-monitoring function risk recommending older-generation products simply because newer variants were not on the radar at recommendation time.

Wider differentiation across insurers requires deeper comparison

Insurers under Use-and-File have moved from broadly similar wordings (the legacy of long tariff and File-and-Use cycles) to materially differentiated variants. A 2025 sample of fifteen current Industrial All Risks wordings across the top six commercial insurers showed substantive variation in: machinery breakdown sub-limit definitions (six different formulations), business interruption indemnity period structures (four different approaches), debris removal limits (per-policy versus per-occurrence variants), terrorism cover terms (in-policy versus pool layered variants), and cyber damage carve-outs (silent, named exclusion, or affirmative cover variants). A comparison memo that does not address these variants is unreliable.

Harder client conversations on policy comparison

Clients confronted with multiple variants on critical wordings often ask the broker to recommend a single best option rather than provide a long comparison. The broker's recommendation discipline must therefore combine wording analysis, claims behaviour expectations on each insurer, premium differential, and the specific risk profile of the client. Defensible recommendation memos run 8 to 18 pages for material commercial placements in 2026, against 3 to 6 pages typical under File-and-Use.

Documentation discipline for IRDAI inspection

IRDAI inspection of brokers in 2025 and 2026 routinely tests whether the broker's recommendation was based on current-generation product comparison and whether the comparison evidence is documented. Brokers presenting comparison memos referencing withdrawn or superseded UINs face observations. Brokers without versioned comparison-memo records linking each placement to the comparison evidence at that point in time face stronger observations. The recordkeeping discipline is part of the broker's operational compliance and should be integrated with the case-management system rather than left to ad-hoc folder structures.

Three IRDAI circulars across 2024 to 2026 have specifically shaped commercial product evolution and broker comparison work.

The IRDAI Master Circular on General Insurance Products dated November 2023 consolidated prior product-related directions into a single reference for insurers and intermediaries. The Master Circular prescribed standardised definitions for material terms (sum insured, indemnity period, deductible, reinstatement, depreciation, replacement value), required affirmative disclosure of any cover that varies from the standardised definition, and tightened the wording-clarity standards. Insurers refiled most current commercial products against the Master Circular through 2024.

The IRDAI Circular dated April 2024 on Policy Wording Simplification introduced plain-language requirements for commercial product wordings, particularly on exclusions, conditions, and policyholder rights. Insurers responded with simplified variants that materially reduced clause length and changed phrasing, with consequential effects on legal interpretation of older versus newer wordings. Brokers running the comparison should review the legal interpretation guidance from their internal counsel or empanelled law firm on each material wording change.

The IRDAI Circular dated November 2025 on Climate-Aligned Product Filing requested insurers to identify the climate-resilience features of commercial property and engineering products, including the cover provided for monsoon-aggravated losses, climate-physical-risk parametric riders, and renewable-energy-specific extensions. The circular has prompted a wave of climate-aligned product variants across 2026 that brokers should specifically test in comparison memos against client climate-physical-risk exposures.

A fourth circular expected in mid-2026 is the IRDAI Circular on AI-Mediated Product Wording, addressing the use of generative AI in product wording drafting and the governance expectations on insurers using AI tools for product design. The circular is anticipated to require insurers to disclose AI-mediated elements of product design and to maintain human review evidence. Brokers should monitor this circular as it lands because it will affect how product wording provenance is documented and how brokers should question variants that may have AI-generated wording elements.

The IRDAI Regulatory Sandbox, established through the IRDAI (Regulatory Sandbox) Regulations 2019 with subsequent amendments, provides a controlled environment for innovative insurance products and processes to operate on a limited basis before broader market launch. Products that complete the sandbox cycle successfully often graduate to Use-and-File status with appropriate adjustments based on sandbox learnings.

The sandbox-to-Use-and-File pathway runs through three stages. The sandbox cohort approval allows the product to launch with specified policyholder count, premium volume, geography, or product feature limits over a 12 to 24 month period. The sandbox review assesses experience against expectations, with specific focus on consumer protection outcomes, loss ratios, and operational viability. The graduation decision determines whether the product moves to standard Use-and-File status, requires further sandbox iteration, or is withdrawn.

Products that have graduated from sandbox to Use-and-File through 2024 to 2026 include:

• Parametric weather covers for crop and infrastructure exposures with index-linked trigger structures.
• Usage-based commercial motor with telematics-driven pricing and dynamic policy adjustment.
• AI-services professional indemnity for technology vendors providing AI-driven services to enterprise clients.
• Climate-physical-risk parametric riders layered onto standard property covers.
• Cyber business interruption variants with specific trigger and waiting-period structures.
• Embedded SME packages distributed through digital partner platforms.

For brokers, the sandbox graduation pathway is relevant because graduated products often carry materially different terms from the sandbox version. Comparison memos referencing sandbox-era product analysis should be refreshed for the graduated variant. Brokers should also track current sandbox cohorts because the next 12 to 24 months will see further graduations affecting commercial product availability.

Use-and-File transfers material responsibility from IRDAI's pre-clearance review to the insurer's internal product governance. The IRDAI Circular on Product Management Committee Composition and Functioning dated 2023 prescribes the governance structure that insurers must maintain.

The product management committee (PMC) is chaired by a Whole-Time Director or equivalent senior executive and includes the appointed actuary, chief underwriting officer, chief risk officer, chief compliance officer, and head of claims as voting members. The committee meets at minimum quarterly and on demand for product approval decisions. The PMC's recorded decision is the regulatory basis for Use-and-File launch.

For brokers, the PMC framework matters because the PMC's decision-making evidence is the primary document IRDAI examines in post-launch review. Where IRDAI finds PMC decisions inadequately reasoned, products may be withdrawn. Brokers comparing variants should consider the maturity of the insurer's PMC framework as one component of insurer selection, particularly for novel or higher-risk product classes where governance strength affects long-term product viability.

The PMC's responsibility extends across the product lifecycle, not just initial launch. Reviews are required at minimum 12-monthly with focus on:

• Loss ratio versus expectation with corrective action where divergence exceeds tolerance.
• Complaint volume and themes with product-design corrective action where needed.
• Claims behaviour including denial rates, dispute frequency, and surveyor feedback.
• Distribution feedback from brokers, agents, and direct channels on product fit.
• Reinsurance support continuity with action if treaty conditions change materially.
• Regulatory environment changes that affect product validity (such as the Master Circular refilings of 2024).

Brokers engaging insurers on product evolution discussions should request evidence of PMC review cadence and outcomes where their clients have material exposure to specific products. Insurers with mature PMC functions typically welcome the engagement because it supports product evolution; insurers with weak PMC functions resist the engagement, which is itself a signal.

Brokers operating in the Use-and-File environment of 2026 should implement four workflow changes if they have not already.

First, establish a product-monitoring function. The function tracks new product launches, withdrawn and modified products, recent IRDAI circulars affecting product design, and current sandbox cohorts. For a mid-market broker, the function typically runs at 0.5 to 1.0 FTE with structured monthly reporting to the placement and advisory teams. Larger brokers run 2 to 4 FTE with sector-specialised tracking.

Second, upgrade the comparison memo template. The template should require UIN capture, wording version, comparison date, analyst, and structured comparison fields covering definitions, scope, key exclusions, sub-limits, trigger language, and special terms. Versioned memos linking to placement records are the audit trail for inspection. A workable memo template runs 12 to 20 fields captured in the broker's case-management system with downloadable comparison documents.

Third, integrate comparison work with case-management. Comparison memos should not live in shared drives separate from placement records. The integration ensures that any placement is traceable to the comparison evidence at that point in time, and any subsequent claim dispute can reference the comparison memo as part of the broker's recommendation defence.

Fourth, train placement and advisory staff on current product variants. Quarterly training sessions covering recent launches, withdrawn products, and any regulatory circulars affecting product design keep the front-line teams current. Untrained teams default to recycled comparison memos and outdated recommendations, with exposure to inspection observation and to client criticism when superseded variants are recommended.

Implementation cost benchmarks

For a mid-market broker with annual revenue of INR 25 crore to INR 100 crore, the incremental cost of Use-and-File-aligned product monitoring and comparison discipline lands at INR 30 lakh to INR 75 lakh annually covering FTE allocation, case-management system upgrades, training, and external advisory. Larger brokers spend INR 1.2 crore to INR 3 crore annually at proportionate scale. The cost is real but small relative to the placement revenue protected by current-generation product recommendations and the compliance exposure reduced by versioned comparison evidence.

To see how Sarvada's broker workflow integrates UIN tracking, comparison memos, and placement records for Use-and-File-aligned advisory work, Request Access to our platform.