Who registers as an IIIO
An IIIO is a financial institution under the IFSCA Act, 2019 that IFSCA has registered to carry on the activities of an insurance intermediary. The IFSCA (Insurance Intermediary) Regulations, 2021 (the IIIO Regulations) are read with the IFSCA (Operations of International Financial Services Centres Insurance Intermediary Offices) Guidelines, 2021.
Registration is granted in one category:
- Insurance distributors: composite broker, corporate agent, direct broker and reinsurance broker.
- Insurance claim service providers: surveyor and loss assessor, and third party administrator.
The applicant may be an intermediary registered with IRDAI, a foreign insurance intermediary registered with its home regulator, an Indian company, firm or co-operative society, or a body corporate incorporated outside India. It may set up as a branch (unincorporated form) or as an incorporated entity. A foreign applicant setting up a branch must hold a valid home registration, have acted in that category, come from a FATF-compliant jurisdiction, be registered in a country with which India has a Double Taxation Avoidance Agreement, and obtain a no-objection certificate from its home regulator. An IRDAI-registered intermediary needs an IRDAI no-objection certificate.
Insurance web aggregators are covered by a separate instrument, the IFSCA (Insurance Web Aggregator) Regulations, 2022.
What an IIIO may do
- A direct broker may act for direct insurance business within the IFSC, from other Special Economic Zones and from outside India. It may not solicit direct business from the Domestic Tariff Area (DTA) except in accordance with section 2CB of the Insurance Act, 1938.
- A reinsurance or composite broker may act within the IFSC, in other SEZs, in the DTA and outside India.
- Third party administrators and surveyors may service only policies issued by an IFSC Insurance Office (IIO) or by an insurer domiciled outside India. A third party administrator may also service foreign travel and health policies of Indian insurers that cover treatment outside India.
- No IIIO may transact a class of business not permitted in its certificate.
All financial transactions of an IIIO are carried out in freely convertible foreign currency other than the rupee.
Capital and professional indemnity
Schedule I to the IIIO Regulations sets minimum capital in US dollars. For a branch, the capital is earmarked and held by the applicant in its country of incorporation.
| Category | Incorporated: capital | Incorporated: net worth | Branch: capital |
|---|---|---|---|
| Direct broker | 100,000 | 80,000 | 10,000 |
| Reinsurance broker | 550,000 | 60% of minimum capital | 55,000 |
| Composite broker | 675,000 | 60% of minimum capital | 67,500 |
| Corporate agent | 75,000 | 75,000 | 7,500 |
| Surveyor and loss assessor | Nil | Nil | Not listed |
| Third party administrator | 550,000 | 150,000 | 55,000 |
Capital must come from owned funds, not borrowings, and the shares or contributions must be unencumbered. A shortfall in net worth must be restored immediately. A capital and net worth certificate is filed half-yearly.
Every IIIO must hold professional indemnity insurance throughout its registration, although IFSCA may allow a newly registered IIIO up to 12 months to buy it. For brokers the limit is twice annual remuneration, subject to a minimum of USD 150,000 for a direct broker, USD 550,000 for a reinsurance broker and USD 700,000 for a composite broker. A branch may rely on its head office policy, endorsed to cover the IFSC operations.
Conduct and client money
- Every intermediary follows the code of conduct in Schedule III. A reinsurance or composite broker must also enter into a terms of business agreement with the (re)insurer covering, among other things, premium payment terms and the handling of client money.
- Where a reinsurance or composite broker collects premium or claims money, it must deal with that money in the manner IFSCA specifies (regulation 20).
- Not more than 50% of remuneration in a financial year may come from any one client, counting associates, subsidiaries and group concerns as one client.
- A change of principal officer or branch head needs IFSCA's prior approval. Mergers, acquisitions and transfers of business also need prior approval, except that a branch whose IFSC business is not being transferred only informs IFSCA within 30 days.
- Registration is valid for three years and must be renewed. Business must start within 180 days of registration; the Chairperson may extend this, but not beyond 18 months.
The IFSCA (Management Control, Administrative Control and Market Conduct of Insurance Business) Regulations, 2023 and the records regulations also apply to IIIOs. Fit and proper and anti-money laundering rules apply as to other regulated entities.
Managing general agents
Managing general agents (MGAs) were first provided for in the IIO registration regulations. They now have a separate code: the IFSCA (Managing General Agents) Regulations, 2026, published in the Gazette on 12 June 2026, which removed the earlier MGA provisions. In IFSCA's description, an MGA is an insurance intermediary with delegated authority from one or more foreign insurers to underwrite direct insurance or settle claims.
- Only a company may register, either a foreign body corporate (for example as a branch) or a company under the Companies Act, 2013. LLPs and partnerships cannot.
- At application the MGA needs at least one written binding authority agreement. Each foreign insurer must have net worth of at least USD 100 million, a rating of at least A for the last three years and a home country with an Indian tax treaty.
- Minimum paid-up or assigned capital is USD 500,000, maintained with an IFSC Banking Unit, and net worth must be the higher of USD 250,000 and 50% of that capital. Before starting business the MGA deposits USD 10,000 plus 10% of its minimum capital with an IFSC Banking Unit, with a lien in IFSCA's favour.
- Premium and claims money goes into a segregated fiduciary account that is outside the MGA's assets on insolvency.
- An MGA may not bind reinsurance or retrocession, participate in syndicates or sub-delegate its authority. Claims over USD 10,000, or involving a coverage dispute, go to the foreign insurer for prior approval.
Applying
Applications are made through IFSCA's single window (SWIT) using the common application form and the insurance intermediary annexure. If IFSCA finds deficiencies it allows 30 days to rectify them, and it will not refuse an application without first hearing written submissions. See SWIT, IFSCA registration and fees. Fees are now set by IFSCA's fee circular of 2 March 2026, as corrected, rather than by the older guidelines.