IMF Registration Benefits and IMF NOC from IRDAI

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The Insurance Marketing Firm (IMF) model is a unique and innovative distribution channel introduced by the Insurance Regulatory and Development Authority of India (IRDAI), which allows the entities to solicit and procure insurance policies while also offering various financial services. Since its inception in 2015, the IMF model has undergone significant changes to expand its reach, enhance financial inclusion, and streamline operations and through this article we will provide a detailed guide to IMF registration in India, its eligibility criteria, process, benefits, and how to get the IMF NOC from IRDA for Name Approval at MCA. Apart from IMFs, the insurance industry consists of various other intermediaries and entities, including:

• Life Insurers

• Non-Life Insurers

• Health Insurers

• Reinsurers

• Foreign Reinsurance Branches

• Brokers

• Corporate Agents

• Surveyors

• Web Aggregators

• Insurance Repository

• TPA (Third Party Administrators)

What are Insurance Marketing Firms (IMFs)?

An Insurance Marketing Firm (IMF) is an entity registered with IRDAI to solicit and procure insurance products, distribute other financial products regulated by SEBI, RBI, Post Office, NPS, and employ individuals licensed to market them. The IMFs are governed under the IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015, ensuring a regulated framework for their operations.

Evolution of the IMF Insurance Company Model in India

The idea of allowing distribution companies to have multiple tie-ups with insurers was first explored by IRDAI in January 2014. A working group was constituted to analyze the feasibility of this distribution model. Following recommendations from the working group, various stakeholders, and the Insurance Advisory Committee, IRDAI officially introduced the Insurance Marketing Firm (IMF) distribution channel on January 21, 2015.

Further, based on feedback from stakeholders, amendments were made to the IMF regulations in January 2017 and July 2019 to enhance operational efficiency and industry adoption.

Source: IRDA

Amendments Under IRDAI Regulations 2022

The IRDAI Insurance Intermediaries (Amendment) Regulations, 2022 were introduced to increase the number of tie-ups available to IMFs and Corporate Agents.

As per the new rules:

• A Corporate Agent (CA) can now tie up with 9 insurers (earlier limited to 3 insurers) in each line of business (Life, General, and Health).

• An IMF can now tie up with 6 insurers (earlier limited to 2 insurers) in each line of business (Life, General, and Health).

• The area of operation of an IMF has expanded from a district-level operation to a state-level.

Scope of Activities of an IMF Company

IMFs are allowed to perform multiple activities under their registration, including insurance solicitation, financial product distribution, and insurance servicing. The scope includes:

1. Solicitation of Insurance Products

• An IMF can solicit insurance products from a maximum of two Life, two General, and two Health Insurers through its Insurance Sales Persons (ISPs).

• It can also tie-up with Agriculture Insurance Company of India Ltd. (AIC) and Export Credit Guarantee Corporation Ltd. (ECGC).

2. Insurance Products Allowed to be Sold by an IMF

• All individual/retail insurance products, including crop insurance for non-loanee farmers and combi products.

• Group insurance products such as Property Insurance, Group Personal Accident, Group Health Insurance, Group Savings Linked Insurance Scheme (GSLI), and Term Insurance for MSMEs.

3. Marketing of Financial Products

IMFs can market financial products through appointed Financial Service Executives (FSEs), including:

• Mutual fund products regulated by SEBI.

• Pension products regulated by PFRDA.

• Other financial products distributed by SEBI-licensed Investment Advisors.

• Banking and financial products offered by banks/NBFCs regulated by RBI.

• Non-insurance financial products offered by the Department of Posts, Government of India.

• Any other financial products permitted by IRDAI from time to time.

4. Insurance Servicing Activities

IMFs are also allowed to undertake insurance servicing activities, such as:

• Activities permitted under the IRDAI (Outsourcing of Activities by Indian Insurers) Regulations, 2017.

• Becoming an Approved Person of Insurance Repositories.

• Other insurance-related activities as permitted by IRDAI.

Eligibility Criteria for Registering an IMF Company in India

To register an IMF in India, an applicant must meet the following criteria:

• The entity must be registered as a Company, an LLP, or a Co-operative Society.

• Capital Requirement:

  • Minimum Rs.5 lakh net worth if opting for an Aspirational district.

  • Minimum Rs.10 lakh net worth for other cases.

• Geographical Presence: Initially, an IMF can operate in one district and expand to two more districts upon renewal, provided one is an Aspirational district.

• The entity must comply with IRDAI’s registration, operational, and reporting requirements.

Clarification on the Name of Insurance Marketing Firm

As per the Insurance Regulatory and Development Authority of India (Registration of Insurance Marketing Firm) Regulations, 2015 (hereinafter referred to as IMF regulations), IRDAI notified the regulatory framework covering the constitution, licensing aspects, governance structure, and enforcement structure of IMFs.

Under Reg. 5.2 (vi) of the IMF Regulations, the applicant must include the words “Insurance Marketing Firm” in its name. However, as per Rule 8 of Companies Incorporation Rules, 2014 issued by the Ministry of Corporate Affairs (MCA) under the Companies Act, 2013, a company name with the word ‘Firm’ is considered undesirable as it implies a different type of business entity. Consequently, such applications may be rejected by the Registrar of Companies (RoC) during incorporation.

In view of this, IRDAI has clarified that the proposed name of an IMF should not include the word “Firm” to ensure compliance with MCA regulations. This clarification has been issued under the powers vested with the Authority under Section 14(2) of the IRDA Act, 1999, read with Reg. 28 of IMF Regulations.

Registration Process for an IMF

The registration process for an IMF involves the following steps:

1. NOC, Company Registration at MCA & IRDA Application Submission

How to Obtain a No Objection Certificate (NOC) from IRDAI

A No Objection Certificate (NOC) is issued by IRDAI to an IMF applicant upon request. The NOC is granted solely for the purpose of allowing the IMF applicant to apply for incorporation of the proposed IMF Firm Name (which must necessarily include the words “Insurance Marketing” or “IMF”) with the Registrar of Companies (ROC). The NOC remains valid for six months from the date of issue.

Steps to Apply for NOC from IRDAI:

Visit the IMF Portal

  • Go to the IMF Portal Home Page.

  • Click on “New User? Register Now!”.

  • Click on “Do You Need NOC? Click Here”.

Fill in the Relevant Details

  • Name of the Proposed Company*

  • Address of the Proposed Registered Office

  • Address of Correspondence

  • Email ID

  • Details and Jurisdiction of ROC

  • PAN

Upload the Required Documents

  • Scanned copy of PAN card of proposed directors/partners.

  • Scanned copy of Aadhaar of proposed directors/partners.

  • Scanned copy of Address Proof of the given Address of Correspondence.

Submit the Application

  • Click on ‘Submit’ to complete the process.

*Important Considerations for Naming the Proposed Company:

• Must include “IMF” or “Insurance Marketing”.

• Must specify its structure, e.g., Pvt. Ltd., OPC, LLP, etc..

• Must not be similar to any Insurer Broker.

• Must not be an undesirable name as per Companies (Incorporation) Rules 2014.

Once the NOC is received from IRDAI, the applicant can proceed with the Company Registration process. Upon successful registration, the Certificate of Incorporation (COI) will be issued by the Registrar of Companies (RoC). Following this, the applicant must submit Form A to IRDAI, along with the necessary below cited documents, to proceed with the IMF licensing process:-

• Incorporation Certificate of the Company/LLP.

• Net worth certificate from a Chartered Accountant.

• Business plan detailing insurance and financial services to be offered.

• Details of Insurance Sales Persons (ISPs) and Financial Service Executives (FSEs).

• Others as may be required

2. Approval & Due Diligence

IRDAI reviews the application for IMF License, verifies the submitted documents, and conducts background checks before granting approval.

3. Grant of Registration Certificate

Once the due diligence is complete, IRDAI issues a Certificate of Registration, allowing the IMF to commence operations.

Benefits of Registering an IMF

1. Expanded Business Opportunities

IMFs can offer insurance and financial products, creating multiple revenue streams through commissions and fees.

2. Increased Market Reach

With the 2022 amendment expanding operational scope to the state level, IMFs can tap into a larger customer base.

3. Diversified Product Portfolio

IMFs can offer Life, Health, and General Insurance along with mutual funds, pension products, and banking products, making them a one-stop solution for financial services.

4. Support from Government & Regulatory Bodies

The IMF model aligns with IRDAI’s objective to increase insurance penetration and promote financial inclusion across India.

Therefore, we can say that the IMF company registration process in India presents a great opportunity for businesses and entrepreneurs looking to establish a regulated financial distribution network. With expanded operational scope, increased tie-ups, and regulatory backing, IMFs serve as an essential distribution channel for insurance and financial services in India. If you're planning to register an IMF, you must check the NOC process & compliance with IRDAI guidelines and leverage the vast potential of the insurance market in India.

FAQs

Q1. What is an Insurance Marketing Firm (IMF) and why is its registration important?

Ans. An Insurance Marketing Firm (IMF) is an entity registered with the Insurance Regulatory and Development Authority of India (IRDAI) to market insurance products and provide related financial services. IMF registration is essential as it allows firms to operate legally, sell multiple insurance products, and offer ancillary financial services such as pension plans and mutual funds. It enhances credibility and ensures compliance with IRDAI regulations.

Q2. What are the benefits of obtaining IMF registration from IRDAI?

Ans. IMF registration provides several benefits, including the ability to sell life, general, and health insurance products, expand the business with multiple insurers, and offer financial advisory services. It also ensures regulatory compliance, improves customer trust, and allows firms to access various government-backed financial schemes. Additionally, IMFs can generate revenue from commissions and fees on financial services.

Q3. What is an IMF NOC from IRDAI, and why is it required?

Ans. An IMF No Objection Certificate (NOC) from IRDAI is a mandatory approval required for entities wishing to operate as Insurance Marketing Firms. It serves as a preliminary clearance confirming that the applicant meets all eligibility criteria, including financial, infrastructure, and personnel requirements. Without this NOC, an entity cannot proceed with the final registration process.

Q4. How can a firm apply for an IMF NOC from IRDAI?

Ans. To apply for an IMF NOC, the firm must submit an online application through the IRDAI portal along with necessary documents such as the business plan, infrastructure details, director and promoter qualifications, and proof of financial stability. The application undergoes scrutiny by IRDAI, and upon meeting all criteria, the NOC is granted, allowing the firm to proceed with full registration.

Q5. What are the key eligibility criteria for IMF registration with IRDAI?

Ans. To register as an IMF, a firm must have a minimum paid-up capital of Rs.5 lakh, a qualified principal officer, and an adequate number of insurance sales personnel. It must also maintain proper office infrastructure and comply with regulatory guidelines for financial integrity and operational efficiency. Additionally, the entity should not have any legal or financial irregularities that could impact its credibility.

Q6. Can an IMF operate with multiple insurers after registration?

Ans. Yes, once registered, an IMF can market products from multiple insurers across life, general, and health insurance categories. This allows the firm to offer a diversified range of insurance solutions, giving customers multiple options and ensuring better service quality. However, the firm must adhere to IRDAI’s code of conduct and maintain transparency in dealings with insurers and policyholders.

Q7. How long does it take to receive an IMF NOC from IRDAI?

Ans. The processing time for an IMF NOC depends on the completeness of the application and IRDAI's scrutiny process. Generally, it takes 30-60 days for IRDAI to review and approve an IMF NOC if all documents and compliance requirements are in order. Any discrepancies in the application may lead to delays, requiring clarifications or additional submissions from the applicant.

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