The three-year expiry date on an IFSC insurance intermediary's Certificate of Registration is gone. From 12 November 2026, Certificates of Registration (CoRs) issued to International Financial Services Centre Insurance Intermediary Offices (IIIOs) will carry continued validity, subject to compliance with the IIIO Regulations, other applicable directions of the Authority and payment of annual fee. The change comes in the circular titled "Clarification for removing ambiguity in the International Financial Services Centres Authority (Insurance Intermediary) Regulations, 2021 ('IIIO Regulations'), pursuant to the Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025." It applies to all IIIOs, it is in force with immediate effect, and it will operate until revised or amended regulations are notified.
Quick Answer: IFSCA's circular F. No. IFSCA-Insu/CIRC/1/2021-Insurance, dated 12 November 2026, ends the three-year validity of Certificates of Registration for International Financial Services Centre Insurance Intermediary Offices. All CoRs will now carry continued validity, subject to compliance with the IIIO Regulations, other applicable directions and payment of annual fee.
What IFSCA has clarified
The circular is short, and its purpose is stated in its subject line: it removes ambiguity. The law governing the validity of an insurance intermediary's registration has changed, while the IIIO Regulations, 2021 still carried the older position. IFSCA has bridged that gap by circular, and the position in the circular will apply until revised or amended regulations are notified.
The circular is F. No. IFSCA-Insu/CIRC/1/2021-Insurance, dated 12 November 2026, issued by IFSCA and signed by Bhaskar Khadakbhavi, Chief General Manager, Department of Insurance and Pension. It was issued in exercise of the powers under sections 12 and 13 of the IFSCA Act, 2019, with the approval of the Competent Authority. It is addressed to all IIIOs, and it is in force with immediate effect from 12 November 2026 — there is no deferred commencement date or transition window in the circular.
Key changes
- The three-year validity period ends. A CoR issued to an IIIO will no longer be limited to three years from the date of issuance. CoRs will now be issued with continued validity.
- Continued validity is conditional, not unconditional. It is subject to compliance with the IIIO Regulations, other applicable directions of the Authority, and payment of annual fee.
- Renewal, where it falls due, still requires an application. An IIIO whose CoR is due for renewal shall file an application to the Authority, as and when due, and the Authority may renew the CoR with continued validity on the same conditions.
- The annual fee is the fee specified under the Fee Circular. An IIIO shall pay such annual fees as specified under the circular titled "Fee structure for the entities undertaking or intending to undertake permissible activities in IFSC or persons seeking guidance under the Informal Guidance Scheme", bearing reference IFSCA-DTFA/1/2026 dated March 02, 2026.
- The circular is interim in form. The new position applies until revised or amended regulations are notified. The circular does not itself rewrite the IIIO Regulations, 2021.
In plain language: an IIIO no longer holds a registration that simply runs out after three years. The registration now continues in force — but only for as long as the IIIO stays compliant with the IIIO Regulations and the Authority's directions, and keeps paying the annual fee.
Why the change was needed: the SBSR Act and section 42D(4A)
The circular sets out its own background, and it explains why a clarification was needed at all. The Insurance Act, 1938, as amended by the Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025 — referred to in the circular as the "SBSR Act" — provides, in particular in sub-section (4A) of section 42D, that the validity of registration granted to an Insurance Intermediary shall remain in force subject to payment of annual fee, unless suspended or cancelled by the Authority.
That is a different model from a fixed-term registration, which has a built-in end date. Under section 42D(4A), the registration remains in force, and payment of the annual fee — together with the absence of a suspension or cancellation — keeps it in force. The circular brings the IIIO position into line with that model, until the regulations are revised or amended.
One background point, clearly labelled as background and not part of the IFSCA circular itself: IRDAI's FAQ on its own Insurance Intermediaries (Amendment) Regulations, 2026 confirms the same three-year-to-continued-validity shift for domestic intermediaries. They are separate instruments from separate regulators; an IIIO should follow the IFSCA circular, not the IRDAI process.
Old vs new: what has actually changed
The comparison below is drawn from two official texts only: the consolidated IIIO Regulations, 2021, and the circular dated 12 November 2026.
The single biggest difference is the removal of the fixed end date. Everything else in the new position is about the conditions that replace that end date: compliance, directions, and the annual fee.
Who is affected
The circular applies to all International Financial Services Centre Insurance Intermediary Offices — every office that holds, or will hold, a CoR as an IIIO. There is no narrower category named in the circular and no distinction between offices at different stages of their registration cycle.
IIIOs applying for a fresh CoR will now receive a CoR with continued validity, rather than a CoR expressed to be valid for three years from issuance. There is no three-year expiry date to diary as the end of the registration, because the registration is expressed to continue, subject to the stated conditions.
IIIOs whose CoR is due for renewal are expressly addressed by the circular. They shall file an application to the Authority, as and when due. The circular does not remove the renewal step; it changes what renewal produces — the Authority may renew the CoR with continued validity, subject to compliance with the IIIO Regulations, other applicable directions and payment of annual fee.
IIIOs in the middle of a current three-year term should check their own CoR and note the circular's in-force date of 12 November 2026. The circular does not set out a separate conversion process for CoRs already issued. If a renewal date is approaching, the renewal application described in the circular is the step that brings the office onto the continued-validity footing.
IIIOs that are not yet registered will apply under the new position, and their CoR, when issued, will carry continued validity on the same conditions. The circular speaks only to validity; it does not state that any other requirement for obtaining a CoR has changed.
What "continued validity" means in practice
Continued validity is easy to misread as permanent validity. The circular does not say that. It states, twice, that continued validity is subject to compliance with the IIIO Regulations, other applicable directions of the Authority, and payment of annual fee.
Compliance with the IIIO Regulations. The IIIO Regulations, 2021 remain the governing regulations for IIIOs. The circular clarifies validity; it does not replace the regulations.
Other applicable directions of the Authority. The second condition covers directions of the Authority that apply to the IIIO, beyond the IIIO Regulations themselves. An IIIO must follow the Authority's applicable directions as well as the regulations.
Payment of annual fee. Instead of a three-year term, the registration remains in force subject to payment of annual fee. The fee is not fixed by this circular: an IIIO shall pay such annual fees as specified under the Fee Circular, IFSCA-DTFA/1/2026 dated March 02, 2026.
Section 42D(4A) reinforces the same point: validity shall remain in force subject to payment of annual fee, unless suspended or cancelled by the Authority. Continued validity does not remove the Authority's ability to suspend or cancel a registration. It means the registration does not lapse merely because three years have passed.
What has not changed
It is just as important to be clear about what the circular does not do. First, it does not rewrite the IIIO Regulations, 2021. It clarifies how validity will be treated under those regulations, pursuant to the SBSR Act, until revised or amended regulations are notified.
Second, the circular does not remove the renewal application for a CoR that is due for renewal. The change is to what the renewed CoR looks like — continued validity rather than a further three-year term — not to whether an application is needed when renewal falls due.
Third, the circular does not state a fee amount, a fee due date, or a renewal deadline. Any figure or date of that kind must come from the Fee Circular or from the Authority's directions, not from this circular. Renewal applications are to be filed as and when due, in the circular's own words.
Fourth, the circular does not change who it applies to. It applies to all IIIOs and does not extend to intermediaries outside the IFSC framework.
What to do next
The steps below follow directly from what the circular states.
- Read the circular and note the in-force date. It is in force with immediate effect from 12 November 2026. Note circular number F. No. IFSCA-Insu/CIRC/1/2021-Insurance, and keep a copy of the official PDF with the office's records.
- Check your own CoR and its renewal position. Identify whether your CoR is a fresh application, a CoR due for renewal, or a CoR in the middle of its term. If a renewal is due, an application to the Authority is required, as and when due.
- If a renewal is due, file the application as and when due. Do not wait for a further notice. The renewal, if granted, will be with continued validity, subject to compliance with the IIIO Regulations, other applicable directions and payment of annual fee.
- Confirm the annual fee from the Fee Circular. Check the fee specified for your office under IFSCA-DTFA/1/2026 dated March 02, 2026, and pay it as specified there. This circular does not state the fee amount.
- Review compliance with the IIIO Regulations and applicable directions. Because continued validity is expressly subject to compliance, confirm that the office is compliant with the IIIO Regulations and with other applicable directions of the Authority.
- Update internal records. Remove any note that treats the CoR as expiring automatically after three years, and record that it carries continued validity subject to the three conditions in the circular. Keep the renewal-due check in place.
- Watch for revised or amended regulations. The new position applies until revised or amended regulations are notified. When that notification issues, read it against this circular and update the office's records.
For advisers supporting IIIOs, the same steps apply: check every client file that still describes IIIO registration as a three-year registration, and correct it to continued validity, subject to the three conditions in the circular.
FAQs
Is the IFSCA IIIO Certificate of Registration still valid for only three years?
No. Under IFSCA's circular F. No. IFSCA-Insu/CIRC/1/2021-Insurance, dated 12 November 2026, all CoRs issued to IIIOs will carry continued validity, instead of being valid for three years from issuance. The continued validity is subject to compliance with the IIIO Regulations, other applicable directions of the Authority and payment of annual fee.
What is the IFSCA circular on IIIO Certificate of Registration validity dated 12 November 2026?
It is the circular titled "Clarification for removing ambiguity in the International Financial Services Centres Authority (Insurance Intermediary) Regulations, 2021 ('IIIO Regulations'), pursuant to the Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025", issued under sections 12 and 13 of the IFSCA Act, 2019, with approval of the Competent Authority, and in force with immediate effect.
Do IIIOs still need to apply for renewal of their Certificate of Registration?
Yes, where a renewal is due. The circular states that an IIIO whose CoR is due for renewal shall file an application to the Authority, as and when due, and the Authority may renew the CoR with continued validity, subject to compliance with the IIIO Regulations, other applicable directions and payment of annual fee.
What annual fee must an IIIO pay under the new continued validity position?
Such annual fees as specified under the Fee Circular, IFSCA-DTFA/1/2026 dated March 02, 2026. The 12 November 2026 circular does not state the fee amount itself.
Does continued validity mean an IIIO registration can never be cancelled?
No. The amended Insurance Act, 1938, in particular section 42D(4A) as amended by the SBSR Act, 2025, provides that the validity of registration shall remain in force subject to payment of annual fee, unless suspended or cancelled by the Authority. Continued validity does not remove suspension or cancellation.
When does the IFSCA IIIO continued validity circular take effect?
It is in force with immediate effect from 12 November 2026, the date of the circular. The circular states that the new position applies until revised or amended regulations are notified.
Who does the IFSCA IIIO Certificate of Registration circular apply to?
It applies to all International Financial Services Centre Insurance Intermediary Offices (IIIOs). The circular is addressed to all IIIOs, and it states that all CoRs shall be issued to IIIOs with continued validity on the conditions set out in the circular.
Sources
- Primary source — IFSCA circular (official PDF): F. No. IFSCA-Insu/CIRC/1/2021-Insurance, dated 12 November 2026 — Clarification for removing ambiguity in the IIIO Regulations, 2021, pursuant to the Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Act, 2025
- Additional official source — IFSCA New Section listing: https://ifsca.gov.in/Home/NewSection
- Additional official source — Consolidated IIIO Regulations, 2021 (official PDF): https://ifsca.gov.in/Document/Insurance/insurance-intermediary-reg-consolidated28012022112903.pdf
Every factual claim in this article is drawn from the official IFSCA circular dated 12 November 2026 and the consolidated IIIO Regulations, 2021. The fee amount is not stated in that circular; it must be taken from the Fee Circular, IFSCA-DTFA/1/2026 dated March 02, 2026.
