The SBSR Act's Rulebook Takes Shape: Tracking IRDAI's June 2026 Exposure Drafts

The Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025 was passed on 17 December 2025 and came into force on 5 February 2026. That commencement changed the Insurance Act, 1938, the IRDAI Act, 1999, and the Insurance Regulatory and Development Authority Act framework at the level of primary law. What it did not do was rewrite the several dozen subordinate regulations through which those statutes actually operate.

This gap is the whole subject of this post, and it is routinely misread. When a headline says a reform is now law, it usually means the enabling power exists, not that the operational rule has been written. Perpetual intermediary licences were a genuine day-one change because the amended Act carried the substance itself. Most of the rest of the Act works differently: it hands IRDAI a power, or removes a constraint on an existing one, and leaves the regulator to draft the regulation that turns the power into a requirement a firm can comply with.

Between mid and late June 2026, IRDAI moved on that backlog in a visible burst, releasing four exposure drafts inside five days. Each opened a short public-comment window, and by mid-July every one of those windows had closed. None of the four has been notified. This is the tracker: what each draft proposes, when its window closed, and what a compliance team should watch for as the drafts move, or do not move, toward final notification.

An exposure draft occupies a specific and often misunderstood place in the regulatory process. It is a proposal published for stakeholder comment. It has no legal effect. Its thresholds, dates, and formats can change before notification, and occasionally a draft is withdrawn entirely and re-issued in a materially different form.

Three distinctions are worth holding onto while reading the four drafts below.

1. Enabling versus operational. The SBSR Act is the enabling layer. These drafts are the operational layer. A reform that appears settled at the Act level may still be undefined in practice until its regulation is notified.
2. Draft versus notified. A notified regulation is published in the Gazette and binds from its stated commencement date. A draft binds no one. Building compliance systems to a draft is prudent as directional planning, but treating a draft requirement as a live obligation is a category error that produces wasted work if the final text shifts.
3. Comment window versus finalisation. A closed comment window means stakeholder input is in. It says nothing about when, or whether, the final regulation appears. IRDAI has not published finalisation timelines for any of these four, and the interval between a closed window and a notified regulation has historically ranged from weeks to well over a year.

IRDAI released the exposure draft of the IRDAI (Registration, Capital Structure, Transfer of Shares and Amalgamation of Insurers) (First Amendment) Regulations, 2026 on 15 June 2026, with comments invited until 6 July 2026. That window has closed.

The draft aligns the registration and capital-structure regulations with the amendments the SBSR Act made in February. Its most consequential element for deal teams is the transferor approval threshold for share transfers in an insurer, which the draft moves from the existing 1 percent to 5 percent, tracking the statutory change. Below the new threshold, a transfer would no longer require the transferor to obtain prior approval. The draft also revisits the bespoke self-certification route that had applied to transfers in listed insurers falling between 1 percent and 5 percent, a route that becomes redundant once the general threshold itself rises to 5 percent.

Why this sits first in the pipeline is not accidental. Registration and capital-structure rules govern who may own an insurer and on what terms, and the SBSR Act's headline liberalisations (including the move toward higher foreign investment participation) cannot operate cleanly until the ownership-transfer mechanics are settled underneath them. For private-equity investors, insurer CFOs, and anyone contemplating a stake sale, the draft changes the arithmetic of when a transaction needs the regulator in the room. It remains a draft, and the precise final threshold treatment for listed and unlisted insurers is exactly the kind of detail that can move on notification.

On 17 June 2026, IRDAI published an exposure draft proposing a framework for how it makes regulations and conducts public consultations, with comments invited until 8 July 2026. This one is different in kind from the other three: it is not about insurers or intermediaries at all, but about the regulator's own process.

The draft proposes to formalise the consultation step that has, until now, been followed as practice rather than prescribed as procedure. Its notable feature is a proposed minimum comment window of 21 days on future exposure drafts. That number is worth pausing on against the four drafts in this very tracker. Draft One ran 15 June to 6 July, roughly three weeks. Drafts Three and Four ran 19 June to 10 July, again roughly three weeks. Draft Two itself ran 17 June to 8 July. The regulator was, in effect, road-testing its own proposed minimum while proposing it.

For firms, a codified minimum window matters more than it appears. Under an unwritten practice, a rushed consultation on a complex regulation could compress industry response to a handful of working days. A prescribed floor gives compliance and legal teams a predictable minimum in which to model impact, coordinate an industry-body submission, and respond substantively rather than reflexively. It also creates a procedural hook: a regulation notified after an unusually short consultation could be argued to sit uneasily with the regulator's own stated process, once that process is itself notified. As with the others, this is a proposal. The 21-day figure is not yet a binding floor.

The exposure draft of the IRDAI (Insurance Intermediaries) (Amendment) Regulations, 2026 was dated 19 June 2026, with comments invited until 10 July 2026. That window has closed.

The draft's substance is a disclosure regime, not a licensing one, and this distinction has been widely garbled in secondary commentary. It applies across the intermediary spectrum: brokers, corporate agents, insurance marketing firms, and web aggregators. Its core proposals are a separate financial-statement schedule splitting revenue from insurance intermediation out from other income or receipts from insurers, submission of audited financial statements with the auditor's report to IRDAI by 30 September each year, and publication of those statements on the intermediary's own website. It also proposes heavier disclosure for intermediaries earning more than INR 10 crore in commissions, creating a two-tier regime.

Two corrections belong here, because both circulate as fact and neither is one. First, this draft does not grant brokers perpetual registration. Perpetual intermediary licences already exist, delivered by the SBSR Act itself from 5 February 2026, and this draft neither creates nor extends that. Second, the draft does not introduce an INR 10,000 corporate-agent registration fee; that figure has attached itself to the draft in some retellings and is not what the disclosure amendment is about. Read against the wider 2026 sequence, the draft is best understood as the data layer: after commission pricing was deregulated in 2023 and the aggregate expense envelope was capped in 2024, this proposal makes intermediary earnings visible and reconcilable. What it is not is a change to who holds a licence or for how long.

Also dated 19 June 2026, the exposure draft of the IRDAI (Insurance Surveyors and Loss Assessors) (Third Amendment) Regulations, 2026 invited comments until 10 July 2026, routed to a dedicated surveyor-registration address. That window has closed.

The draft proposes to replace the surveyor's fixed-term registration cycle with perpetual registration subject to an annual fee, with amounts in the region of INR 1,000 and INR 5,000 cited in the draft for the recurring charge. Structurally, it mirrors for surveyors the move the SBSR Act already made for intermediaries: a registration that continues until surrendered, suspended, or cancelled, rather than one that expires and must be renewed on a clock.

It is important to keep the surveyor and intermediary cases distinct, because they are at different stages. Perpetual licensing for brokers and other intermediaries is in force, delivered by the amended Act. Perpetual registration for surveyors is, as of this writing, only a draft proposal in a subordinate regulation. A firm that treats the surveyor change as settled is reading a proposal as a rule. The practical stakes for insurers and brokers sit in claims-panel management: the periodic renewal of a surveyor's licence has functioned as a recurring quality checkpoint, and if that checkpoint is replaced by an annual fee, the burden of assessing continuing surveyor competence shifts more squarely onto the entities that empanel them. That is a consequence to plan for, but only if and when the draft is notified in something like its current form.

Four drafts in five days is a burst, not a completion. Several strands of the SBSR Act's reform still had no accompanying exposure draft as this tracker was written, and their absence is as informative as the four that appeared.

The most watched gap concerns commission and remuneration. The SBSR Act restored IRDAI's statutory power to cap distributor commissions, a power it had lost in the earlier deregulation. Reporting through mid-2026 indicated the regulator was preparing a consultation on restructuring commissions themselves (including staggered trail payouts and effort-based remuneration), but that consultation is distinct from the intermediary disclosure draft above and had not itself been issued as a notified framework. The disclosure draft creates the data; any commission-structure intervention would be a separate instrument built on it.

Other enabling changes at the Act level also await their operational regulations. The higher foreign-investment participation the Act permits needs its conditions and reporting mechanics settled in subordinate rules and in the foreign-investment framework administered outside IRDAI. Provisions touching how insurers may organise, merge, and hold non-insurance interests continue to work through their own regulatory sequence.

The honest reading of the pipeline is therefore incremental. The June drafts cleared the most procedurally foundational items (registration mechanics, the consultation process itself, intermediary disclosure, and surveyor registration) while the commercially heaviest question, what happens to commissions, was still upstream. A compliance team mapping its own exposure should not assume the June burst represents the full operationalisation of the Act. It represents the first tranche.

Because none of the four drafts is notified, the useful posture is monitoring rather than compliance. A practical watch-list for a broking firm, insurer compliance team, or investor:

• Finalisation, not just closure. A closed comment window is the start of the wait, not the end of it. Watch IRDAI's notifications for the Gazette-published final text of each regulation, and read the final against the draft rather than assuming they match. Thresholds and dates are the fields most likely to move.
• The registration draft's threshold treatment. For anyone contemplating a stake transaction, the exact final position on the transferor approval threshold, and how it treats listed versus unlisted insurers, is the operative detail. Do not price a deal on the draft's 5 percent figure until it is notified.
• The consultation framework's fate. If the procedure-for-making-regulations draft is notified with a firm minimum comment window, it changes how every subsequent draft should be tracked. If it is diluted or dropped, the industry stays on the regulator's discretion.
• The intermediary disclosure timeline. The 30 September filing date in that draft collides with typical audit calendars. Watch whether the final text keeps the date, adds a transition year, or moves it, because the answer decides how much lead time broking finance functions actually have.
• The commission consultation. This is the one to watch hardest, precisely because it had no June draft. When and how IRDAI issues it will shape distribution economics more than the four drafts here combined.