Photo of Indranath Bishnu

Indranath Bishnu

Partner (Head – Insurance) with Cyril Amarchand Mangaldas. His work is focussed on the Insurance industry where he specializes in mergers and acquisitions and joint ventures and regulatory matters. He is currently leading the team from Cyril Amarchand Mangaldas engaged to advise the Regulation Review Committee constituted by the General Insurance Council and the Life Insurance Council in relation to overhauling and consolidating the regulatory framework issued by the IRDAI. He has advised various government bodies including Department of Financial Services (Ministry of Finance) and the IRDAI on reforms in the insurance sector. He currently serves as a member on the committee constituted by the IRDAI to study and recommend capital requirements for Insurance entities. On the transactional side, Indranath advises multiple corporations, both Indian and foreign, in relation to investments in the insurance sector as well as establishment, operation, management and control of insurance companies and intermediaries in India. He can be reached at indranath.bishnu@cyrilshroff.com

Listing of Insurance Brokers in India: The Need for an Explicit Framework

Summary: The blog notes that while India’s insurance framework does not prohibit broker listings, due to the absence of explicit IRDAI guidance, the insurance brokers may have limited access to public markets. While recent reforms (such as perpetual registration) address some hurdles, the 25% investor cap under brokers regulations may create a tension with SEBI’s minimum public float requirement. The piece suggests that it may be helpful for IRDAI to consider a clear, conditions-based listing framework for brokers, drawing on existing models for insurers and the proposed pathway for TPAs.

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Insurance Ombudsman and the Case for Consent-Based Mediation

Summary: The Ministry of Finance published the Draft Insurance Ombudsman (Amendment) Rules, 2025 (“Draft IO Amendment Rules”), for public consultation in November 2025, which continue to remain in draft form. The Draft IO Amendment Rules proposed significant amendments to the current regime, including digitisation measures, enhanced penalties, and establishment of an appellate authority to entertain appeals against awards passed by the Ombudsman. We revisit the basic principles regime, with mediation as its cornerstone, highlight areas of ambiguity, and analyse the direction of Draft IO Amendment Rules are taking.

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IRDAI sets up performance scorecard for KMPs: A case for indirect enforcement

The IRDAI published a circular on Remuneration to Key Management Persons, dated May 25, 2026 (“Circular”). This was soon after a concept paper revisiting the remuneration of Key Managerial Personnel (“KMP”) of Indian insurers was shared among a select group of stakeholders, inviting their comments. The Circular, which is now applicable law, amends the IRDAI Master Circular on Corporate Governance for Insurers, 2024 (“Master Circular”). The Circular has been issued in exercise of powers under Section 34 of the Insurance Act, 1938, Section 14 of the IRDA Act, 1999, and Regulation 12 of the Regulations.

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Amended Cyber Security Guidelines for Insurance Sector: Key Amendments and What They Mean for Regulated Entities

Summary: On April 6, 2026, IRDAI issued certain amendments to its 2023 Information and Cyber Security Guidelines for insurance sector, while retaining the core structure of the guidelines. This article covers the key changes to the guidelines and their implications for regulated entities such as expanded Board accountability, introduction of IT Steering Committee, enhanced independence of CISO, and targeted relaxations for Foreign Reinsurance Branches etc

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API Integration in Insurance: Unlocking Digital Policy Distribution

Summary: This article examines the increasing use of Application Programming Interfaces (“APIs”) in the insurance sector and their role in enabling embedded and digital distribution models. It discusses how API platforms are integrated for distribution of insurance products with third-party digital platforms, offering coverage at the point of transaction. The article also highlights the key legal and operational considerations arising from such arrangements and outlines the regulatory framework under the Insurance Act, 1938.

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Directors and Officers Liability Insurance Policy in India: Key Practical Considerations

Summary: This blog provides a comprehensive overview of Directors and Officers Liability Insurance policies in India, highlighting their coverage structure and associated nuances. It examines critical practical considerations, including knowledge attribution, coverage for past officers, fraud exclusions and the importance of truthful disclosures. It seeks to guide individuals on their rights as policyholders and aid them in entering into new policies or renegotiating their existing policies.

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Investment Functions of Insurers and Insurance Brokers: On A Short Rope or Ample Wiggle Room?

Summary: This blog broadly outlines the IRDAI’s prescriptive investment framework for insurers, permissible asset classes thereunder, limited applicability to insurance brokers, and the regulatory intent behind these norms. It also highlights proposed amendments to the investments regulatory framework, granting insurers greater flexibility to invest in private companies while maintaining governance safeguards. For comprehensive, insurer-specific, or instrument-specific details, it is important to refer to the full text of IRDAI’s investments regulatory framework.

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100% FDI in Insurance: Getting the Ground Ready

Summary: The Ministry of Finance has proposed significant amendments to the Indian Insurance Companies (Foreign Investment) Rules, 2015, marking the latest regulatory move towards enabling 100% foreign direct investment in insurance companies. This follows Finance Minister Nirmala Sitharaman’s Budget 2025-26 announcement to review and simplify FDI guardrails and conditionalities, representing a significant shift in India’s approach to foreign investment in the insurance sector. Our blog analyses the key proposals and implications for insurers/ intermediaries and stakeholders from a regulatory standpoint.

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IRDAI Regulatory Reform Series: Rural, Social Sector, and Motor Third-Party Obligations

The Insurance Act, 1938 (“Insurance Act”), includes special provisions obligating insurers to mandatorily source a part of their business from persons residing in rural areas; workers in the unorganised or informal sector, or from economically vulnerable or backward classes of the society.[1] Insurers are also required to underwrite a minimum percentage of insurance business for third-party motor insurance policies, both under the Insurance Act[2] as well as the Motor Vehicles Act, 1988 (“MV Act”).[3] These requirements were, until recently, implemented through two distinct regulations issued by the Insurance Regulatory and Development Authority of India (“IRDAI”) – the IRDAI (Obligation of Insurer to Rural and Social sector) Regulations, 2015 (“RSO Regulations”), and the IRDAI (Obligation of Insurer in Respect of Motor Third Party Insurance Business) Regulations, 2015 (“MTP Regulations”).

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