How to appoint a Principal Officer for Insurance Web Aggregator

  • February 04, 2021
  • Registrationwala

How to appoint a Principal Officer for Insurance web Aggregator? IRDA License has one primary requirement and it’s the Principal officer. Know the answer to how to appoint or change them.



Starting an insurance web aggregating business involves adhering to lot compliances, one of which is appointing an Insurance web aggregator. Without this aspect fulfilled, the company doesn’t have the eligibility to apply for the Insurance web aggregator license ergo doesn’t have the ability to start an Insurance web aggregation portal. 

Thus, through this guide, we are going to answer the question of how to appoint a Principal Officer for an Insurance Web Aggregator. 

What is an insurance web aggregator?

If you go by the traditional definition, you’d think that a  principal officer is someone who heads the insurance web aggregation company. Although you won’t be wrong in that assumption, the technical definition is a bit more nuanced than this one. 

According the Regulation 2(i) of the IRDAI regulations that were established in 2017, the definition of principal officer for a company is:

  1. A director or the partner of said company who has to bear the exclusive responsibility of operation of insurance web aggregation. 

  2. A CEO or Chief Executing officer of the company whose is responsible for supervising all the tasks required from insurance web aggregator business. 

In short, the principal officer is the driver of the insurance web aggregator business – ensuring that the business adheres to the clause of displaying insurance policies as products and providing insurance comparison module to the users. 

How qualified a Principal officer is required to be?

As per the rules of the IRDAI, a Principal Officer has to have the following educational qualifications to lead the Insurance web aggregator company:

  1.  Must have either a bachelor’s degree or a master’s degree in the fields of Arts, Science, commerce, Engineering, Social Science, Law, management or something equivalent to those fields from any university of institution. However, the university or institution has to be recognized by either the state or the central government, or 

  2. Must be a fellow or associate of the Insurance Institute of India, Mumbai, or

  3. Must have acquired the master’s qualification from the Institute of Insurance and Risk Management, Hyderabad or,

  4. Must be a member of the ICAI or Institute of Chartered Accountants of India, New Delhi, or

  5. Must be a part of the Institute of Cost and Works Accountants of India, Kolkata, or

  6. Must be a part of Institute of Company Secretaries of India (ICSI), New Delhi, or 

  7. Must be a part of Institute of Actuaries of India, or

  8. Must have acquired a Certified Associate ship of the Indian Institute of Bankers (IIB), Mumbai, or

  9. Must have the required qualification provided by the IRDAI mentioned in the IWA regulations. 

In addition to the above qualifications, the principal officer must also have acquired training from  an Institute recognized by the Insurance Regulatory Development Authority of India and must have cleared the exam, and have the results to show for it. 

What is required from the Principal officer before the Insurance Web Aggregator Application can be filed?

With respect to the Insurance web aggregators, there are some requirements that must be fulfilled if you’re to file the application of Insurance web aggregation. Without fulfilling the below mentioned requirements, IRDAI would have no choice but to reject your application:

  1. The educational requirements as mentioned above must be fulfilled by the Principal officer of the company. 

  2. The Principal Officer must undergo the additional insurance training as mentioned above by an institute that has IRDAI’s stamp of approval. 

  3. The Principal officer should be of a sound mind and body. In legal terms, he should come under the “Fit and Proper” Criteria . It’s not just about sound mind and body, the principal officer should also not be convicted of any crime or has any pending investigations in the Department of Revenue Intelligence. 

  4. While the consultants will file the application, it’s the Principal officer that has to appear before IRDAI – representing his case to acquire the registration. 

How is a Principal Officer Appointed

Appointment of Principal officer goes hand in hand with filing the application of Insurance web aggregator registration. Meaning that when the documents are being submitted, the documents pertaining to the Principal officer are considered enough in terms of process of appointing the principal officer. 

Here is the list of document specific to the appointment of the principal officer:

  1. Circum Vitae of the Principal officer

  2. Copies of the qualification documents of the Principal officer

  3. Self Certification by the Principal officer that he or she is not in any way prior related to the insurance industry (other than education), and thus is not ineligible to apply for the Insurance web aggregator IRDA license. 

  4. Results and training certificate received from IRDAI approved institute regarding insurance web aggregator platform. 

  5. An undertaking that states that:

    1. Prior application for registration hasn’t been rejected by IRDAI

    2. No codes has been violated by the Principal officer that are mentioned in the IRDAI regulations. 

    3. The only reason Principal Officer is appointed is to execute the functions of the company. 

    4. The principal officer is not the director, CEO, or assigned or represented any other company that does the same Insurance web aggregator business. 

  6. An information sheet containing all the details of the Principal officer

  7. An information sheet that highlights and specifies all the responsibilities of the principal officers including

    1. Qualification

    2. Achievements

    3. Experience

    4. Equity Interest in the company

    5. Directorship details if held in previous companies.

What are the Compliances of Insurance Web aggregator specific to Principal officer

Every year, the Principal officer must submit a Certificate of confirmation to the IRDAI. It would state that the company has adhered to all the regulations mentioned in the IRDAI act during that financial year. 

How to change the Principal Officer

To change the principal officer, approval must first be obtained from the IRDAI. The Company applying for change should file an application for the same – giving the reason why does it want the change to happen. 

In what circumstances the Principal officer can be disqualified?

Under the following circumstances, the Principal officer can be disqualified:

  1. The PO is a minor

  2. The PO doesn’t fit the “fit and proper” criteria

  3. The PO has been found to have a criminal history associated with Financial crimes

  4. The PO has committed, whether knowingly or unknowingly, a fraudulent act. 

  5. The PO has not provided correct qualification details

  6. The PO hasn’t passed the insurance exams

  7. The PO has contravened the code of conduct associated with Insurance web aggregation. 

What are the points in the Code of conduct that a Principal officer has to abide by?

There are four matters of code of conduct that a Principal Officer of an Insurance web aggregator company has to abide by at all times. Failing to do so might lead the IRDAI to disqualify them:

  1. Code of Conduct pertaining to client relationship

  2. Code of conduct pertaining to handling complaints

  3. Code of conduct pertaining to advertisement

  4. Code of conduct pertaining to training

Code of conduct pertaining to client relationship

  • Each deal conducted with clients must be good faith

  • The Deal should be conducted with care and diligence

  • All the information provided by the client must be confidential 

  • It’s the principal officer’s responsibility to keep the client’s information confidential. 

  • The client should be informed about the risks and rewards of each insurance policy

  • the PO should provide any conflict of interest i.e. must knowingly avoid dealing with anyone that can compromise the integrity of the business. 

Code of conduct pertaining to handling complaints

  • The company should have a repository to record the complaints. 

  • The website should entail all required information and specify the option to the client to file the complaint

  • The website has to acknowledge any complain within 5 days of receiving it. 

  • The company should deal with the complaint to the client’s satisfaction. 

  • Once the complaints are resolved, the company must send a resolution letter to the complainant. 

  • It’s the Key Management Person’s job to handle the complaints.

Code of Conduct pertaining to advertisement

It’s the Principal officer’s responsibility to ensure that the Insurance web aggregation website doesn’t contain any advertisements or any biased information. 

Code of conduct regarding receipt of remuneration

The principal officer must disclose the amount of remuneration received once the insurance policy is sold to the client. 

Code of conduct pertaining to training

  • The staff of the insurance web aggregator company should be aware of the regulations and follow them to the tee

  • Each and every staff member should receive adequate training

  • Each member of the staff has to be evaluated using a specialized system.

  • Each member of the staff must be familiar with the legal requirement associated with the functioning of the company. 

  • The client should be informed or made aware that the company has signed the Section 41 of the Insurance act – prohibiting any share of commission

  • Copy of this code of conduct must be pasted in every office. 

  • The PO should file the annual returns of the Company within 15 days of the period specified by the Insurance authority (IRDAI)

Principal officer’s role in renewing the IRDA license

For the renewal of the Insurance web aggregator license, the Principal Officer should undergo the required renewal training. It has to be done 6 months in advance of the end of license validity. 


A principal officer is the lifeblood of an Insurance web aggregation company. If the officer slips and breaks any regulations or the code of conduct, the entire company has to suffer. That’s why, it’s important to be familiar with the code and take pro-active steps as suggested by Registrationwala to always stay compliant to them. That way, your insurance web aggregator company would always be seen in the positive light by the IRDAI. 

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