India’s Distribution Reset: An Actuarial Perspective on Commissions, Persistency and Customer Value

India’s insurance industry relies significantly on various distribution channels beyond direct sales to drive new business. According to reports published by IRDAI, India’s agent-led distribution network has significantly risen in the last decade, with numbers reaching as many as 54 lakh distributors across life, health and general insurance.

An insurance policy is a long-term contract, but its distribution economics can be heavily front-loaded. In simpler words, the insurance agents may end up collecting a significant chunk of commission in the initial years of selling a policy. This results in a mismatch: While distributors may earn a significant portion of their remuneration in the initial years, the economic impact of the sale is reflected in the insurer’s and policyholder’s experience over the entire policy term.

Regulatory Announcement

A New Direction on Insurance Commissions

IRDAI’s recent proposal, issued on September 24, 2026, focused on reintroducing commission caps for distributors, which were previously removed in 2023. Another significant development is the intention of the regulator to pay higher remuneration on complex insurance products.

Pause & Reflect 🧠

So What Changes From An Actuarial Perspective?

Can we simply assume that a fall in commissions would automatically result in a fall in premiums?

Would there be any other impact on the policy sold and its stakeholders?

 

We will explore these questions here. So, put on your thinking caps, and let’s dive in! 🎩


Understanding Commission Through An Actuarial Lens

The most direct way in which commission features in actuarial work is through its treatment as an expense assumption in product pricing. The key components typically considered in pricing include:

Premium = Expected Cost of Claims + Expenses + Cost of Capital + Profit Margin

Until now, insurers have been paying most of this commission component to distributors upfront, i.e., at the very beginning of policy sale. This may increase the insurer’s new business strain, as a higher proportion of expenses is incurred upfront, with the expectation that these costs will be recovered through premiums over the policy term.

However, a policyholder may lapse earlier than expected, resulting in the insurance company not recovering the expense incurred (in the form of commissions) while selling the policy.

This is why it becomes extremely important to distribute commissions throughout the policy term instead of front-loading them, which is where IRDAI’s proposal holds commendable value.


But Is It Really That Simple? Looking Beyond Lower Commissions and Premiums

At first glance, the equation above suggests a straightforward relationship: a reduction in commission lowers expenses, which, in turn, could translate into lower premiums. However, the impact is not quite that simple. From an actuarial perspective, there are three ways to look at this change.

1. Increased profitability for the insurer

This one is relatively straightforward.

Reduced commission
→
Lower acquisition cost
→
Potentially better profitability

2. Impact on sales volumes and product mix

The impact may not stop at acquisition costs. Changes in commission structures could alter the incentives faced by distributors, which may influence the volume and mix of business sold.

Altered commission structure
→
Changed distributor incentives
→
Potential changes in sales volumes and product mix
→
Different overall economics

There could also be a shift towards more complex products where the remuneration structure provides greater incentives, which may raise questions around product suitability and customer needs.

3. Impact on the customer value of the insurance policy

A more evenly distributed commission structure could also change the incentives for distributors over the life of the policy. If remuneration is linked more closely to policy duration, there may be greater incentives to support policyholders in remaining insured.

Better distribution of commission throughout the policy term
→
Better alignment of distributor incentives
→
Improved persistency
→
Potentially better customer value

For an Actuary, the above impacts are important to consider.


Will lower commission always result in lower premiums?

While it is easy to mathematically assume that a lower commission will always result in lower premiums, that is not always the case.

Say the insurer is saving ₹100 right now by reducing the commission paid to brokers. There are other ways it can put the ₹100 to use without lowering the insurance premium.

$\bullet \quad$They can retain this ₹100 as profit margin.

$\bullet \quad$They can invest in technology or improving after-sales services.

$\bullet \quad$They can potentially invest in a new distribution channel, like increasing their marketing budget.

This is potentially one of the criticisms of IRDAI’s proposal: While this move is expected to lower insurance premiums, that may not be a guaranteed outcome.


What should you, as Actuaries, consider going forward?

We have already discussed the impact of this insurance overhaul from an Actuarial perspective. But for Actuaries, assumption setting is an important practice, and this move is expected to impact exactly that.

Every distribution channel produces a different customer profile. They may differ in:

$\bullet \quad$persistency;

$\bullet \quad$product mix;

$\bullet \quad$average policy size;

$\bullet \quad$acquisition cost;

$\bullet \quad$servicing requirements; and

$\bullet \quad$customer behaviour.

Therefore, a change in distribution strategy could ultimately change the underlying experience of the portfolio, which may, in turn, require assumptions used in pricing and future experience analysis to be revisited.


The Bigger Question

The debate around insurance distribution can easily become a debate about numbers.

But the actuarial perspective asks us to look beyond the percentage.

An insurance policy is a long-duration financial contract. The cost of acquiring that policy is only one part of its economics. The more important question is whether the distribution model produces sustainable business that creates value for the customer, distributor and insurer over the life of the contract.

So, the real test of the proposed changes may not simply be whether commission rates fall. It will be what happens to:

Persistency  •  Acquisition Efficiency  •  Product Pricing  •  Profitability  •  Customer Outcomes

once the insurance overhaul is implemented.

For Actuaries, this is an opportunity to look at commission rate capping through a slightly different lens. Not simply as an expense. And perhaps, that is the key question:

“Are we measuring the cost of selling an insurance policy, or are we measuring the value of successfully keeping the customer insured?”


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