Agent Ki Awaaz: send your comments to IRDAI before 25 October
By Ankeet Bahety · 18 Oct 2026
IRDAI is asking the public for comments on its insurance distribution reform paper. Agents are the people these rules affect most, so our voice matters. Comments close on 25 October 2026.
Below are suggested answers to six of IRDAI's 32 consultation questions, written from an agent's point of view. Each is under IRDAI's 250-word limit. Please read them, change anything you disagree with, and add a line from your own experience. Comments in your own words carry more weight than copies.
How to submit (takes about 10 minutes)
- Online: open iib.gov.in/dr, go to Section 17 (Consultation Questions), paste your answer under each question number, then use Review and Submit at the bottom of the page.
- Excel: on the same page, click "Download Excel to Submit", fill in your answers, and upload it using "Upload Your Response (Excel)".
- Email: send your comments to drfeedback@iib.gov.in, with the question number before each answer.
You can answer only the questions you care about. Leave the rest blank.
Suggested answers
Question 16 · Distribution Commission Framework (Section 8)
Has open architecture served its purpose or is it simply increasing costs without adding any significant value for the end customer? Is there more that can be done in this area than proposed in the consultation paper.
Open architecture adds value only when the customer actually gets a choice at the point of advice. For most families, that point is their agent. I suggest allowing individual agents to represent up to three insurers in each segment (life, health and general), with the same training, suitability and record-keeping duties that apply today. When an agent can compare more than one insurer, they can match the product, price and claim service to the client instead of selling the only option they hold. This increases competition between insurers on value rather than on commission, and keeps accountability with the agent because every policy is tagged to the person who sold it. This matters most in smaller towns, where the local agent is often the only adviser a family has. Choice there should not depend on reaching a large broker or a website.
Question 19 · Distribution Commission Framework (Section 8)
Do the proposed commission limits arrive at a fair balance between policyholders' expectations of affordability and distributors' expectations of adequate remuneration?
The limits should reward the work that protects policyholders after the sale, not only the first sale. 1. Health renewals: an agent who keeps a family insured year after year, helps with claims and stops policies from lapsing adds real value. A slightly higher renewal limit for health policies that stay with the same agent would reward persistency and service, and discourage churning clients between policies. 2. Small-business group health: SME group policies need constant servicing, including adding and removing members, endorsements and claim support. Small employers have no HR team for this. The framework should recognise servicing of these policies, so that small businesses keep getting help and are not left unserved because the economics do not work. Both measures are paid for by better persistency and fewer lapses, which also lowers costs for insurers and policyholders.
Question 20 · Distribution Commission Framework (Section 8)
Within the proposed commission limits, which are the possible measures to incentivize good market conduct? Vice-versa, what measures can be built in to disincentivize bad market conduct?
Good conduct: create a public clean-record badge for agents with no upheld complaints, low lapse rates and complete suitability records over, say, three years. Customers could see it on Bima Sugam and insurer websites. This costs nothing in commission and gives customers a simple way to choose a trustworthy adviser. Bad conduct: clawback on mis-sold or cancelled policies is fair, but it must follow due process. Before any mis-selling finding is recorded against an agent or made public, the agent should be told the complaint, see the evidence and have a right of reply within a fixed time. Many complaints arise from claim rejections or product terms the agent did not control. A short hearing step protects honest agents while still acting firmly against those who mis-sell.
Question 25 · Creating awareness against Mis-selling (Section 11)
Are the illustrations of mis-selling appropriate? Please suggest specific measures to disincentivize this.
The illustrations are useful. To disincentivise mis-selling effectively, measures should be targeted by channel, based on complaint and lapse data, rather than applied equally to every distributor. Publish complaint ratios, early lapse rates and free-look cancellation rates by channel and by distributor. Where a channel shows higher mis-selling, such as insurance bundled with loans or sold at the point of another transaction, apply stronger checks there: recorded consent, a cooling-off call from the insurer and a clear statement that the purchase is optional. Individual agents who work with their clients over many years should not carry the compliance burden designed for high-volume channels. A data-led approach puts effort where the problem actually is, and protects customers faster.
Question 28 · Market Infrastructure Institutions for Insurance (Section 13)
Do you agree with the role of MII as a systemic intervention for recalibrating economics of insurance distribution? Please suggest the nature of services you would like to be available on this platform.
Yes. One service that would help every policyholder and every distributor is a free, standard suitability form on Bima Sugam. The proposed suitability check before every sale is a good step. If each insurer and distributor builds its own form, costs rise and quality varies. A single, simple form on Bima Sugam, free for agents and customers to use, would give every sale the same documented needs analysis, store it with the policy record, and make it easy to review if a complaint arises later. Other useful services: a single view of all policies held by a family, renewal reminders, claim status tracking, and the agent's registration details and clean-record status, so customers can verify who they are dealing with.
Question 15 · Expense of Management Framework (Section 7)
Does the sector need a longer timeframe to achieve the proposed norms?
Yes, for distributors. Whatever final limits are notified, there should be a transition period of at least 12 months from the date the final regulations are published before the new commission structure applies to distributors. Agents and small intermediaries need time to adjust their businesses, understand new product sheets and suitability requirements, and complete any training needed. Insurers need time to update systems, contracts and reconciliation processes so that commission paid and commission received match. A clear, predictable timeline avoids disruption to policyholder service, especially renewals and claims support, during the change. It also matches the stated intent of an orderly transition to a better system.
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Join nowSource: IRDAI consultation paper on distribution reforms, published on the Insurance Information Bureau portal, iib.gov.in/dr. These are my suggestions as an agent, not legal advice. Read the full paper before you submit. Insurance is the subject matter of solicitation. See also what the reform means for policyholders.