corporate law

IRDAI dispenses with hard copy submission of Actuarial & reinsurance returns

Introduction
The Insurance Regulatory and Development Authority of India (IRDAI) has issued a circular aimed at simplifying the submission process for actuarial and reinsurance returns. With immediate effect, insurers are no longer required to submit hard copies of related documents. This move is part of a broader effort to digitize regulatory filings and reduce compliance burdens. The updates are grounded in legal provisions under section 14(2)(e) of the IRDAI Act, 1999.

Key Updates on Submission Requirements

Elimination of Hard Copy Submissions

  • Insurers are no longer required to send physical copies of actuarial or reinsurance-related reports and documents to the IRDAI Head Office.
  • PDF and Excel versions must be submitted through centralized portal submissions, email for exceptions.

Digital Signatures and Document Authentication

  • All PDF documents must be digitally signed by the designated signatories.
  • Each page does not require separate initials or digital signatures—a single digital signature for the document suffices.

Continued BAP Portal Submissions

  • Insurers must continue filing returns through the Business Analytics Project (BAP) portal, following current procedures.

Master Circular on Actuarial, Finance, and Investment Functions (May 17, 2024)

The new Master Circular consolidates and updates earlier guidance, introducing several important changes:

Expanded Return Requirements

  • Insurers must now submit additional digitally signed documents in prescribed formats, including:
    • Actuarial Report and Abstract (ARA)
    • Financial Condition Report (FCR)

Updated Timelines

  • Annual returns must be submitted:
    • Within 30 days of Board approval of accounts, or
    • Within three months from the financial year-end,
      —whichever is earlier.

Discontinuation of Select Returns (November 24, 2023)

  • IRDAI discontinued the filing of certain non-essential returns for insurers and brokers.
  • This change aims to reduce compliance efforts, but does not apply to actuarial or reinsurance-related submissions.
  • Mandatory submission of IBNR and FCR reports annually was introduced

Ongoing Digitalization Initiatives

  • IRDAI is expanding its digital infrastructure to streamline filings through its portals.
  • The BAP portal has been upgraded with enhanced functionality and integrated into a broader unified compliance portal.
  • Full transition to digital-only submissions are expected in early 2025, with email-based processes to be phased out over time.

Reinsurance Guidelines and Broader Regulatory Shifts

  • In February 2025, IRDAI released updated reinsurance placement guidelines focusing on:
    • Cross-border reinsurers, and
    • Collateralized reinsurance transactions
  • While these updates do not directly alter actuarial or reinsurance return submissions, they reflect a broader shift in regulatory priorities.

Risk-Based Capital Framework (August 2023)

  • IRDAI introduced technical guidance for implementing the Indian Risk-Based Capital (IRBC) Framework.
  • While the new framework may impact future actuarial reporting, it has not yet replaced the current solvency reporting requirements.

Conclusion
IRDAI's latest circular and associated updates mark a significant step toward a fully digital, streamlined regulatory environment for insurers. By reducing paperwork, enhancing submission efficiency, and clarifying reporting timelines, these measures are expected to improve compliance management across the insurance sector. Insurers should stay updated with future guidance as India transitions further into a digital-first regulatory landscape.