The Insurance Regulatory and Development Authority of India (“ IRDAI/ Authority” ) has issued a circular dated April 6, 2026, bearing reference number IRDAI/GA&HR/CIR/MISC/51/4/2026 (“ Circular ”) on the IRDAI Information and Cyber Security Guidelines, 2026 (“ Guidelines, 2026 ”).
The key highlights of the Circular are as follows:
- The Guidelines, 2026 revise the earlier framework titled ‘IRDAI Guidelines on information and Cyber Security for Regulated Entities’ dated April 24, 2023, bearing reference number IRDAI/GA&HR/GDL/MISC/88/04/2023 (“ Guidelines, 2023 ”) in the light of evolving threat landscape, industry feedback and recommendations of various IRDAI committees, with the objective of strengthening defence and governance mechanisms to deal with emerging cyber threats.
- The Guidelines, 2026 are applicable to all insurers including FRBs, Insurance Intermediaries covering Brokers, Corporate Agents, Web Aggregators, TPAs, IMFs, Insurance Repositories, ISNP, Corporate Surveyors, MISPs, CSCs and Insurance Information Bureau of India (“ IIB ”), requiring adherence to the prescribed standards and ensuring compliance from the current financial year.
- The Guidelines, 2026 also set out the revised controls for preparation of the Auditor’s Report.
The changes introduced in the Guidelines, 2026 are as follows:
Summary of Modifications
| Sl. No. | Relevant Provision | Existing Provision | Changes Introduced | Revised Provision |
|---|---|---|---|---|
| 1 | 1.4. Applicability – FRBs | No specific framework for FRBs | New provision for compliance by FRBs |
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| 2 | 1.5. (II) Governance | II. Governing BoardThe ISRMC meeting shall require CISO and at least two members to participate with all members meeting at least twice in a year. | Frequency has been increased from twice in a year to quarterly basis. | The Information Security Risk Management Committee (ISRMC) shall meet at least on a quarterly basis. |
| 3 | 1.6.(1) Roles and Responsibilities – Board of Directors | 1. Board of Directors(Roles and responsibilities of Board of Directors) | Additional responsibilities have been introduced including budget allocation, monitoring of cyber risks and ensuring closure of gaps. |
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| 4 | 1.6.(3) Roles and Responsibilities – CISO | 3. Chief Information Security Officer (CISO) The CISO shall be responsible for carrying out the following functions: Briefing to the ISRMC CISO shall review and approve requested exceptions to information security policies, standards and procedures. | These provisions are modified and new additional responsibilities has been prescribed. | Provisions have been amended to –
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| 5 | 1.6.(4) Roles and Responsibilities – CTO | 4. Chief Technology Officer (CTO) CTO was responsible for information security rated technology implementation of the organization. | Provision amended to introduce detailed roles and responsibilities of CTO and align implementation responsibilities with CISO oversight. | 4. Chief Technology Officer (CTO)/ Head of IT Functions:
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| 6 | 1.6.(5) Roles and Responsibilities – CITSO | 5. Chief IT Security Officer (CITSO) Requirement for designation of a CITSO with defined roles and responsibilities. | Provision amended to remove requirement of designated CITSO. | 5. Chief IT Security Officer (CITSO) The requirement of having a CITSO designation has been removed. However, organizations to ensure all functions envisaged to be done by the erstwhile CITSO are adequately discharged by the designated personnel. |
| 7 | 1.6.(7) Roles and Responsibilities – CSO/Admin/ Head Administration | 7. Chief Security Officer (CSO)/ Admin/ Head Administration | Provision amended to provide for detailed roles and responsibilities of Regulated Entities (REs) to adopt enhanced controls. | 6. Chief Security Officer (CSO)/ Admin/ Head Administration
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| 8 | 1.6.(13) Roles and Responsibilities – Functional Head/Business Owner | 13. Functional Head/Business Owner | Provision amended to provide for additional responsibilities of Functional Head and Business Owner. | 12. Functional Head/Business Owner
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| 9 | 1.6.(14) Roles and Responsibilities – ISRMC | 14. Insurance Security Risk Management Committee (ISRMC) The Committee shall provide relevant periodic assurances to the Control Management Committee (CMC). | Provisions amended to require reporting of cyber security audit non-conformities with closure timelines and to shift periodic assurance reporting from CMC to the Risk Management Committee (RMC). | 13. Insurance Security Risk Management Committee (ISRMC)
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| 10 | 1.6.(14) Roles and Responsibilities – ITSC | No provision relating to constitution of an IT Steering Committee (ITSC) | The Provision has been introduced requiring establishment of an IT Steering Committee with senior level representation from IT and business functions. | 14. IT Steering Committee (ITSC)
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| 11 | 1.6.(15) Roles and Responsibilities – CMC | 15. Control Management Committee (CMC) | The provision has been amended to provide for detailed roles and responsibilities of CMC. | 15. Control Management Committee (CMC) The requirement of Control Management Committee (CMC), a board level committee, is done away with, however, Organizations are required to ensure that all functions envisaged to be done by the erstwhile CMC are part of Risk Management Committee (RMC) terms of reference. |
| 12 | 1.6.(16) Roles and Responsibilities – IEE | No existing provision | The provision has been introduced requiring introduction of IEE to be the part of RMC. | 16. Responsibilities – Independent External Expert (IEE) shall be inserted. Considering the importance of Cybersecurity in rapidly changing technological landscape, one or more Independent External Expert (IEE) having substantial IT and/or Cybersecurity expertise in managing or guiding IT/Cybersecurity related initiatives or projects, shall be a part of RMC. |
| 13 | 1.9.(II) Exceptions | II. Exception grant and risk assessment methodology | In this respect, structured timelines and a tiered approval mechanism based on duration of exceptions (up to 3 months, beyond 3 months, and beyond 1 year) have been introduced, along with requirements for periodic reassessment and documentation of associated risks. | Exceptions not exceeding three months shall be approved by the Chief Information Security Officer (CISO) of the organisation. Exceptions exceeding three months shall be approved by the Risk Management Committee (RMC). Further, exceptions exceeding one year shall be approved by the Board of Directors of the organisation. Also, it is required that any exception request exceeding 12 months must undergo a reassessment and re-approval process. All exceptions granted should formally document risk associated with granting such exceptions. |
| 14 | 1.10. Compliance | The Insurance Intermediary shall submit the Annexure – III along with compliance thereto and the comments of the board to the Insurer/s annually. | Additional compliance requirement introduced mandating Insurance Intermediary to submit Annexure -III along with compliance thereto and comments of the Board to the Insurer/s annually. | Clause (b) is inserted.
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| 15 | 2.0. Security Domain Policies | No such existing provision | Detailed description of Policies inserted. | This section is a guidance document for Regulated Entities to frame their own policies, specifying appropriate and adequate security controls along with the applicable standards. The policies shall encompass each of the security domains provided and shall be a part of their approved Information and Cyber Security Policy. |
The changes introduced in the Auditors Report under Annexure -III of the Guidelines, 2026 are as follows:
| Sl. No. | Control number and Area | Changes Introduced | Revised Control |
|---|---|---|---|
| 1 | 32- Security Continuous Monitoring & Detection (DE.CM): | New control introduced | Group companies’ infrastructure, networks, and databases are logically and/or physically segregated, and where a vendor provides services to group companies, IT personnel with cross-entity access are segregated, wherever possible. |
| 2 | 96- Security Continuous Monitoring & Detection (DE.CM): | Addition to existing controls | Is External Grey/White box Penetration Testing (PT) conducted for all internet facing information assets or systems at least once in 6 months by a CERT-In empanelled Auditor. |
| 3 | 97- Security Continuous Monitoring & Detection (DE.CM): | New control has been introduced | Whether, in cases where PT is conducted in a test environment due to unavoidable circumstances, the organization ensures that the test environment’s version and configuration resemble the production environment for VAPT, and any deviations are placed before the ISRMC for approval? |
| 4 | 110- Asset Management (ID.AM) | New control has been introduced | Does the organization maintain an up-to-date inventory of its cryptographic assets to ensure preparedness for transition to post quantum cryptographic environments? |
| 5 | 148 – Supply Chain Risk Management (ID.SC) | New control has been introduced. | Whether the Regulated Entity, through SLAs, requires service providers/outsourced entities to obtain prior written permission before any further outsourcing. |
| 6 | 149 – Supply Chain Risk Management (ID.SC) | New control has been introduced. | Is the Cloud Service Provider (CSP) MeitY empaneled CSP and holds a valid STQC (or any other equivalent agency appointed by Government of India) audit status? |
| 7 | 150 – Supply Chain Risk Management (ID.SC) | New control has been introduced. | Has the organization signed NDA with CSP covering all aspects relating to privacy, confidentiality, security and business continuity? |
| 8 | 151 – Supply Chain Risk Management (ID.SC) | New control has been introduced. | Does the organization contractually require that the cloud service provider will completely eliminate any trace of data/information in disks, backups, etc., at the termination of the contract? |
| 9 | 204 – Information Protection Processes and Procedures (PR.IP) | New control has been introduced as to whether appropriate hardware backup available? | Is appropriate immutable backup and Failover/Resilient components available for critical hardware? |
The Circular also released the brief summary of major changes introduced under Annexure A, and IRDAI Information and Cyber Security Guidelines, 2026 under Annexure B.
A copy of the Circular, Annexure A and Annexure B has been attached herewith for your ready reference.
Source category: IRDAI


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