The Insurance Regulatory and Development Authority of India (IRDAI) has consistently aimed to enhance insurance penetration across all sections of Indian society. Recognizing the need for a simplified and scalable distribution model—especially in semi-urban and rural areas—IRDAI explored options similar to Independent Financial Advisors (IFAs) in 2014, led to the introduction of a new regulatory framework known as the IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015, notified on 21st January 2015, regulations laid the foundation for the creation of Insurance Marketing Firms (IMFs), allowing eligible entities to register with IRDAI and operate as multi-insurer, multi-product distribution units.
IRDAI (Registration of Insurance Marketing Firm) Regulations, 2015 (IMF Regulations) were notified in the Gazette on 21.01.2015. The Authority launched an online portal on 26th May, 2015 for facilitating the applicants to submit their applications through the portal.
Under these regulations:
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Entities registered as a Companies, LLPs Registration, or Cooperative Societies with a minimum net worth of Rs. 05/10 lakh were permitted to register as IMFs.
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IMFs were structured to operate at a district level, encouraging localized insurance penetration through grassroots engagement.
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Each IMF was allowed to partner with a maximum of two Life Insurance Companies, two General Insurance Companies, and two Health Insurance Companies.
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These partnerships enabled the IMF’s team of Insurance Sales Persons (ISPs) to solicit policies and offer customer servicing on behalf of the insurers.
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In addition to insurance distribution, IMFs were also permitted to distribute other financial products regulated by SEBI, PFRDA, or RBI through their trained Financial Service Executives (FSEs).
The IMF Registration thus became an important pillar in IRDAI’s mission to foster financial inclusion and increase insurance awareness and accessibility, especially in underserved regions of the country.
What is the Aspirational District Requirement in the IMF ?
If an IMF applies for more than one district, it is mandatory that at least one of those districts must be an Aspirational District as identified by NITI Aayog, Government of India. Aspirational Districts are districts identified by the government as socially and economically underdeveloped, based on parameters like:
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Health & Nutrition
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Education
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Agriculture & Water Resources
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Financial Inclusion
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Skill Development
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Basic Infrastructure
The program aims to transform these districts through targeted intervention and improved service delivery, and IRDAI’s requirement aligns with this national priority by encouraging insurance outreach in such areas.
If an IMF wants to register for 3 districts in Uttar Pradesh:
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It can choose Lucknow, Varanasi, and must include Bahraich (an Aspirational District) as one of the three.
Refer to the official list of aspirational districts (List given by NITI Aayog).
Objectives of the Insurance Marketing Company (IMF Company) Distribution Model in India
The Insurance Marketing Firm (IMF) model was introduced not just as a new licensing category, but as a transformational insurance distribution channel. Designed with a focus on accessibility, scalability, and entrepreneurship, the IMF framework seeks to promote insurance inclusion across every demographic and geographic segment in India.
Some of the key objectives of the IMF framework include:
1. Enhancing Retail Insurance Reach
IMFs are permitted to sell all individual and retail insurance products, helping bridge the gap between insurers and underserved populations. For commercial insurance, the IMF’s scope is limited to MSMEs, thus enabling them to support India’s small business ecosystem.
2. Encouraging Cross-Selling through Product Diversification
The IMF model is uniquely structured to offer both insurance and other financial products such as pension schemes and mutual funds (as allowed by relevant regulators). This diversification encourages cross-selling, allowing IMFs to provide bundled solutions and generate multiple revenue streams.
3. Providing Servicing Opportunities
IMFs are authorized not only to sell policies but also to undertake policy servicing activities on behalf of insurers. This includes claim support, documentation assistance, and renewal reminders—creating recurring business opportunities and stronger customer relationships.
4. Low Entry Barriers to Attract Entrepreneurs
With a low net worth requirement (Rs.5–10 lakh) and minimal infrastructure norms, the IMF channel is an entrepreneurship-friendly model, particularly suitable for young professionals, local businesses, and financial advisors looking to legally distribute insurance and financial products.
5. Promoting Rural and Tier-2 Penetration
The district-level approach to IMF registration was strategically crafted to extend insurance services deep into rural India. With a community-driven and relationship-based selling style, IMFs were envisioned as the face of insurance in rural and aspirational districts, fostering awareness and trust in formal financial protection instruments.
6. Expanding Insurers’ Business & Servicing Networks
The IMF model is equally beneficial for insurers, offering them a ready-made local distribution and service partner. It empowers them to extend their market coverage without opening costly branch offices, thereby reducing distribution costs and improving customer retention.
Major hurdle Faced by Insurance Marketing Firms (IMFs) while registration with IRDAI
While the Insurance Marketing Firm (IMF) model was conceptualized as a simplified and scalable distribution platform, its on-ground implementation has highlighted several operational, regulatory, and financial challenges. Feedback from active IMFs and insurers has brought out the following key difficulties hampering the widespread adoption and growth of the IMF ecosystem:
1. Cumbersome NOC and Approval Process
The process of obtaining the mandatory No Objection Certificate (NOC) from IRDAI can often be time-consuming and complex, particularly due to coordination required with the Ministry of Corporate Affairs (MCA). While IRDAI may approve a proposed name for IMF registration, final incorporation depends on MCA’s clearance, which may reject a name that is too similar to existing entities. Hence, it is crucial to check the name availability on the MCA portal before applying for the NOC to avoid unnecessary delays.
Many applicants face prolonged wait times and communication bottlenecks during this dual-approval process, which can significantly hinder the timely launch of their Insurance Marketing Firm.
At Compliance Calendar LLP (CCL), we assist businesses in navigating the end-to-end process of obtaining IMF NOC from IRDAI, for smooth coordination between IRDAI and MCA approvals for faster and compliant registration for IMF Company.
2. Limited Awareness on Tie-Up Procedures
IMFs often encounter confusion and lack of clarity when entering tie-ups with insurance companies. Due to insufficient information or guidance regarding insurer-level processes, many IMFs find it difficult to complete the registration smoothly—even after IRDAI approval.
3. Restrictions on Insurer Tie-Ups Limit Growth
Currently, IMFs are allowed to tie up with a maximum of two life, two general, and two health insurers, which restricts the range of insurance products an IMF can offer, thereby limiting customer choice and business expansion. Moreover, this impacts their ability to retain talented Insurance Sales Persons (ISPs), who often seek more versatile sales portfolios.
4. Difficulties in Changing Insurer Tie-Ups
Many insurance companies do not include exit clauses or clear termination provisions in their agreements with IMFs. This leads to legal and operational challenges when an IMF wishes to switch partnerships, hindering flexibility in the evolving insurance market.
5. Limited Geographical Expansion Due to Aspirational District Mandate
Although the IRDAI permits an Insurance Marketing Firm (IMF) to operate in up to three districts, there is a specific regulatory condition attached: at least one of the selected districts must be classified as an ‘Aspirational District’, as per the list published by NITI Aayog. While the intent behind this mandate is to improve insurance outreach in underdeveloped regions, it has also created practical challenges for IMFs aiming for strategic expansion.
In certain states, aspirational districts may already have a high concentration of IMFs, leading to market saturation. In other cases, these districts may lack the infrastructure or population density to support viable business operations, making them less attractive for new firms. This constraint can limit an IMF's flexibility in targeting growth-centric locations.
Net Worth Requirements Based on Area of Operation
The IRDAI has also prescribed differential net worth requirements depending on the geographical scope of operations:
For single-district IMFs (only in an Aspirational District):
A minimum net worth of Rs.5 lakh is required.
For IMFs operating in multiple districts or any non-aspirational district:
A higher minimum net worth of Rs.10 lakh is mandatory.
Regardless of the area of operation, the prescribed net worth must be maintained at all times during the validity of the registration. IMFs are also required to submit a Net Worth Certificate annually, duly certified by a Chartered Accountant, within three months from the end of each financial year.
6. Financial Burden Due to Mandatory ISP Compensation
IMFs are required to pay ISPs a fixed salary equivalent to the minimum wage. While this regulation supports fair employment, it increases the financial burden on small or newly established IMFs, making it harder to hire additional ISPs or scale operations during the early phases of business.
7. Inadequate Remuneration and Lack of Expense Support
Remuneration structures offered by insurers to IMFs are not on par with other intermediaries such as corporate agents or brokers. Additionally, general and health insurers are not obligated to reimburse ISP-related expenses, putting more financial strain on IMFs managing field operations.
8. Limited Permission to Undertake Servicing Activities
Although regulations allow IMFs to undertake servicing activities on behalf of insurers, in practice, many insurers do not permit IMFs to perform these functions. This restricts revenue generation and undermines one of the core advantages of the IMF model—continuous client servicing and retention.
9. Uncertainty Around FSE Appointments and Financial Product Sales
There exists significant confusion regarding the appointment of Financial Service Executives (FSEs), their roles, and the range of financial products they are allowed to sell under different regulatory frameworks. As a result, IMFs struggle to find qualified and willing professionals who can take up these responsibilities effectively.
What is the scope of Activities Permitted to Insurance Marketing Firms (IMFs) companies ?
The Insurance Marketing Firm (IMF) model, governed by IRDAI regulations, offers a wide-ranging scope of activities that goes beyond insurance sales alone. It enables IMFs to operate as a multi-product distribution channel, with the authority to market insurance, financial products, and even undertake servicing responsibilities, detailed breakdown of what an IMF is allowed to do:
1. Insurance Product Distribution through ISPs
IMFs are allowed to solicit insurance products from a maximum of six insurers, including:
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Two Life Insurance Companies
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Two General Insurance Companies
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Two Standalone Health Insurance Companies
In addition to these partnerships, IMFs may also tie up with specialized government-backed insurers such as:
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Agriculture Insurance Company of India Ltd. (AIC)
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Export Credit Guarantee Corporation of India Ltd. (ECGC)
Types of Insurance Products IMFs Can Sell:
1. Individual and Retail Products
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Life, Health, Motor, Travel, and other standard retail insurance plans
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Crop insurance policies (especially for non-loanee farmers)
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Combi products (bundled offerings combining multiple covers)
2. MSME-Focused Products
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Property Insurance
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Group Personal Accident
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Group Health Insurance
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Group Savings Linked Insurance Scheme (GSLI)
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Group Term Life Insurance customized for Micro, Small, and Medium Enterprises (MSMEs)
3. Distribution of Financial Products through FSEs
IMFs are also authorized to market a variety of non-insurance financial products through trained and appointed Financial Service Executives (FSEs). These include:
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Mutual Fund Products of SEBI-registered Mutual Fund Companies
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Pension Products regulated by Pension Fund Regulatory and Development Authority (PFRDA)
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Financial products offered by SEBI-licensed Investment Advisors
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Banking and Financial Products of Banks and NBFCs regulated by the Reserve Bank of India (RBI)
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Non-insurance products sold by the Department of Posts, Government of India
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Other financial instruments as permitted by IRDAI from time to time
This diversified product basket allows IMFs to serve as one-stop financial advisors, offering bundled solutions tailored to the financial goals of customers.
4. Insurance Servicing Activities
Apart from product sales, IMFs can also undertake insurance servicing functions, as per the IRDAI (Outsourcing of Activities by Indian Insurers) Regulations, 2017. These activities include:
Permitted Servicing Activities:
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Servicing responsibilities on behalf of tied-up insurers, such as:
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Customer onboarding
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Claims assistance
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Policy renewals
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Documentation and premium collection support
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Becoming an Approved Person of Insurance Repositories, enabling them to assist policyholders with digital policy records and updates
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Any other insurance-related servicing activity as may be notified or permitted by IRDAI in the future
Why Is the Broad Scope Important?
The broad spectrum of activities permitted under the IMF license makes it a powerful, scalable, and financially viable model for professionals and entrepreneurs looking to enter the insurance and financial advisory space. With the ability to combine product selling and post-sale servicing, IMFs are better equipped to build long-term customer relationships, generate repeat business, and contribute to India's financial inclusion mission.
Therefore, the core philosophy behind the Insurance Marketing Firm (IMF) company lies in its holistic approach to insurance penetration—by combining a wide range of insurance products with customer servicing and financial product distribution and this complementary blend of offerings is what makes the IMF model uniquely positioned to bridge the insurance gap across India.
To unlock its full potential, both pillars of the IMF framework—insurance distribution & servicing and other financial product offerings—need to be revitalized with renewed focus, innovation, and regulatory support. Incentivizing IMFs through balanced remuneration, simplified processes, and enhanced awareness among insurers and the public will be key to driving sustainable growth. With active participation from all stakeholders—IRDAI, insurers, intermediaries, and the entrepreneurial community—there’s no doubt that the IMF model can scale new heights. As awareness improves and ecosystem support strengthens, the IMF channel is well poised to become a cornerstone of India’s financial inclusion and insurance outreach strategy.