IRDA/ BRK/ CIR/ INSRE/ 211/ 09/ 2017
7th September, 2017
CEO’sof all insurers, insurance intermediaries and Insurance Repositories
Re: Clarifications on
a) revisedguidelines on Insurance Repositories and electronic issuance of insurancepolicies dated 29.05.2015
b) Guidelineson insurance e-commerce dated 9th March, 2017
The Authority as part of itsdevelopmental mandate and to reach out to the policyholders in a cost efficientmanner has taken number of steps. This includes issuing revised guidelines oninsurance repositories, insurance e-commerce, issuance of electronic insurancepolicies, maintenance of electronic records, etc.
The Authority has beenapproached by various stakeholders seeking clarity on some of the issues surroundingthese guidelines. Looking into the issues raised by the stakeholders theAuthority issues the following clarifications pertaining to revisedguidelines on Insurance Repositories and electronic issuance of insurancepolicies dated 29.05.2015.
I. Revised guidelines onInsurance Repositories and electronic issuance of insurance policies dated29.05.2015
1. Electronic signature – Clause 60(b) and Annexure 11 ofthe revised guidelines on Insurance Repositories and electronic issuance ofinsurance policies dated 29.05.2015 gives the form for opening of eIAaccount. This form is to be signed by the applicant at the time of opening ofeIA.
Asper current practise, an e-signature of the eIA holder on the application formfor opening an eIA is considered as a valid authentication. However the IRDAI(issuance of e-Insurance policies) (First Amendment) Regulations, 2016 dated 2ndDecember, 2016 provides an option of validation by ‘One Time Password’ forelectronic signature on e-proposal form. Therefore in order to facilitateopening of e-insurance account through online/ electronic means, the Authority permitsvalidation by ‘One Time Password’ for eIA opening as an alternative toe-signature under clause 60(b) and Annexure 11 of the revised guidelines onInsurance Repositories and electronic issuance of insurance policies dated29.05.2015.
2. One Time Password (OTP) basede-KYC for opening of e-Insurance Account (eIA) - Attention is drawn to Guidelines onInsurance e-commerce dated March 9, 2017 which requires insurance policies tobe issued in electronic form and credited to e-Insurance Account (eIA) of thepolicy holder. This requires Insurance Repositories to facilitate online openingof eIA using valid KYC document.
Clause 15(10)(b) of the sameguidelines dated March 9, 2017 stipulates compliance to the KYC/ AML guidelines byusing any of the options given.
In light of the abovestipulation, the Authority substitutes the following for clause 22(d)(i) of therevised guidelines on Insurance Repositories and electronic issuance ofinsurance policies dated 29.05.2015 for opening of an eIA:
(i) Compliance to the KYC/ AML guidelines issued by theAuthority can be undertaken by any of the following facilities:
a) e-KYCfacility offered by UIDAI as given in Authority’s circular no. IRDA/ SDD/ CIR/MISC/ 204/ 08/ 2017 dated 31st August, 2017.
b) validKYC documents permitted under Authority’s circular no. IRDA/ SDD/ GDL/ CIR/175/ 09/ Oct/ 2015 dated 28th September, 2015 or by any othercircular issued by the Authority from time to time.
c) any other facility recognisedby the Authority.
3. Email Id / Mobile Number – Clause 15(11)(b) of the Guidelineson Insurance e-commerce dated March 9, 2017 requires creation of eIA and givesoption to customer to provide either an email id or mobile number. Asper Annexure – 5, Clause 4 (b) of revised guidelines on InsuranceRepositories and electronic issuance of insurance policies dated 29.05.2015,email id and mobile number are both mandatory to open eIA as InsuranceRepository is required to send OTP1 on the registered email id and OTP2 on theregistered mobile number of the eIA holder. In order to bring consistencybetween the two guidelines, the Authority allows opening of eIA on the basis ofeither email id or mobile number with only one OTP being sent to email id/ mobilenumber.
II. Guidelines on insurancee-commerce dated 9th March, 2017
4. Clause15(10)(b)(ii) recognises e-PAN facility offered by NSDL for compliance to theKYC/ AML guidelines issued by the Authority. The same is deleted as it is notone of the recognised mode for KYC/ AML compliance.
5. Clause 15(11)(a)of the Guidelines on insurance e-commerce dated March 9, 2017 stipulates that creationof an e-insurance account shallbe undertaken within 15 days post selling of insurance policies on theapplicant~s ISNP. There are varied interpretations in the market about the saidclause. It is hereby clarified that opening of e-insurance account for allpolicies that are sold on the ISNP Platform has to be necessarily andcompulsorily followed up with opening of an e-insurance account within 15 dayspost selling of insurance policies. Any non-compliance will be seen as aviolation of the aforesaid guidelines.