IC-38 and agent licensing

What is IC-38?

IC-38 is the label most people in Indian insurance use for the agents' pre-recruitment examination and its study course. The code comes from the Insurance Institute of India (III), which IRDAI recognises as the examination body for agents and for staff of corporate agents, web aggregators and insurance marketing firms. A person who wants to become an insurance agent must complete the insurer's training and pass this examination before the insurer can appoint them.

People still speak of an "IRDAI licence", but since the Insurance Laws (Amendment) Act, 2015, IRDAI no longer issues licences to individual agents. The insurer appoints the agent after the exam, and IRDAI keeps a central database of all agents.

How agent licensing works today

Under Section 42 of the Insurance Act, 1938 and the IRDAI (Appointment of Insurance Agents) Regulations, 2016:

1. Eligibility. The applicant must be at least 18 and meet the education requirement in the insurer's board-approved agency policy. The regulations suggest a Class 10 pass as the minimum. The applicant must not suffer any disqualification under Section 42(3), such as being of unsound mind or having been found guilty of criminal misappropriation, breach of trust, cheating or forgery.
2. Training. The insurer provides pre-recruitment training on the syllabus prescribed by IRDAI for life, general or health insurance. The regulations suggest at least 25 hours. Insurers set the actual hours in their agency policy.
3. Examination. The applicant takes the agency examination in the relevant subject, conducted online by the recognised examination body. Remote proctored exams were allowed on a pilot basis in 2020. A candidate who wants to be a composite agent for life and general, for example, must pass in each subject.
4. Pass certificate. The examination body issues a pass certificate, valid for 12 months for seeking a first appointment with any insurer.
5. Appointment. The insurer checks PAN against IRDAI's central and blacklisted agent lists, then issues an appointment letter, agency code and identity card, and updates the IRDAI portal.

The exam format, fee and pass mark are set by the examination body and change from time to time. Check the current details with the insurer or III before booking.

Related certifications

The 2026 refresher training rules come from the IRDAI (Insurance Intermediaries) (Amendment) Regulations, 2026, notified on 30 July 2026. They apply to sellers employed by intermediaries, not to individual agents appointed by insurers.

What IC-38 means for distribution

• The exam is a filter, but a low one. Passing shows basic knowledge of insurance principles, products, regulation and ethics. It does not show that the person can find customers or explain a product well. Insurers that treat the exam as the end of training tend to see weaker activation.
• Time from interest to code is a leak. Every week between a recruit's first meeting and the issue of an agency code loses candidates. Agency teams track exam booking, pass rates and days to code by recruiter and branch.
• Pass rates reveal training quality. Low first-attempt pass rates in a branch often point to rushed training or poor candidate selection rather than a hard exam.
• The 12-month window matters. A pass certificate that is not used for an appointment within 12 months lapses, so candidates recruited for later batches may need to retake the exam.
• Post-licence training is where selling skills are built. Product knowledge, need analysis, objection handling and digital tools are better taught in the first 90 days of agency, alongside real cases, than crammed before the exam.
• Reform may change the structure. IRDAI's September 2026 consultation paper proposes cost-efficient training and a single framework of Insurance Distribution Persons, with functional identities issued through market infrastructure instead of IRDAI registration. The examination requirement for agents is not proposed to go away, but its delivery could change.