Use and file product approval

What is use and file?

Use and file is a way of bringing an insurance product to market in which the insurer does not need IRDAI's prior approval. The insurer's own Product Management Committee, a board-constituted committee, approves the product, a Unique Identification Number (UIN) is assigned, and the product can be sold. The regulator reviews filings afterwards and can order changes or withdrawal. The IRDAI (Insurance Products) Regulations, 2024 define it as the route where the insurer may "launch the product to market after assignment of unique identification number (UIN) and without prior filing to the Authority".

The opposite route is file and use: the insurer files the product with IRDAI and may market it only after filing and allotment of a UIN, after the regulator has examined it.

How use and file works in India

Use and file was introduced in steps. In 2022, IRDAI extended it to all health insurance products, most general insurance products, and most life insurance products, with some exceptions. The Insurance Products Regulations, 2024, in force from 1 April 2024, consolidated six earlier product regulations and made the board-level governance permanent.

The 2024 regulations require each insurer to have:

• Board-approved policies on product design, underwriting, advertisements and product management.
• A Product Management Committee (PMC) that checks pricing principles and target market fit, approves use and file products, recommends file and use products for filing, reviews product performance and grievances, and decides on modification or withdrawal.
• Annual review by the Appointed Actuary of every product on sale, with results presented to the PMC.

IRDAI keeps the power to direct an insurer to withdraw any product that is not in policyholders' interest.

Which life products are use and file

For life insurers, the Master Circular on Life Insurance Products (12 June 2024) lists the new product categories allowed under use and file:

Certain modifications to file and use products, such as some changes to rates or charges within limits, can also be made under use and file.

What use and file means for distribution

• Faster launches. Use and file removes the wait for regulatory review before launch. Distribution teams see more frequent launches and variants, especially in term plans and ULIPs.
• Training load rises. More products and more frequent changes mean more product training for agents and bank staff. Insurers that send simple feature summaries and comparison sheets with each launch help field teams keep up.
• The insurer owns the risk of a bad design. With no prior regulatory approval, a poorly designed product, or one that sells badly or draws complaints, is the insurer's responsibility. The PMC must review grievances and market conduct. Channels that see a product creating complaints should feed this back quickly, because it can lead to withdrawal.
• Check the UIN. Every product and rider must carry a UIN, quoted in all documents given to customers. A sales illustration or brochure without a valid UIN, or with an old version number, should not be used.
• Withdrawn versions. When a product is modified, the old version is withdrawn for new business before the new one launches. Sales teams should not continue selling a withdrawn version, and existing policyholders stay on their original terms unless an option is offered.
• Savings and annuity products move slower. Because non-linked savings, pension and annuity products for individuals remain on file and use, launches in these categories still depend on IRDAI's review timeline.