IRDAI's consultation paper on distribution reforms is open for public comment until October 25, 2026. Anyone can respond, not only insurers and distributors. The paper runs to two parts, it proposes the biggest change to insurance commissions in years, and a submission from a policyholder carries a kind of evidence the regulator cannot get from the industry: what selling actually looked like on the ground.

Method and data basis

Built by reading the IRDAI document page for the paper and its two PDFs (Part 1 and Part 2) directly, plus our coverage of the draft as reported by CNBC-TV18, Livemint, Moneycontrol and Business Standard between September 24 and 26, 2026. The deadline of October 25, 2026 is stated in the paper and in that coverage. Nothing below is a legal opinion, and the wording in the PDFs governs over any summary, including ours.

Where the documents are

  • The paper is published at irdai.gov.in under its consultation papers section, with Part 1 and Part 2 available as PDFs on the same page.
  • IRDAI also runs a Comments on Exposure Drafts section on its website, and it routinely publishes the comments it receives, so treat your submission as a public document and write it accordingly.
  • Keep a dated copy of what you send, and save any acknowledgement. If the process asks for your details, give them; anonymous submissions are easy to set aside.

What makes a comment get read

  1. Name the clause and the number. "Renewal commission at 5 percent will push agents to ignore existing customers; set it at 10 percent" is usable. "Commissions are too low" is not.
  2. One page, one argument each. Pick two or three points and make them properly rather than five points badly.
  3. Use a real example. What was sold, by whom, in what channel, and what it cost you. Numbers and a date beat adjectives.
  4. Separate levels from timelines. The cap percentage and the five-year glide path are different questions. Comment on both.
  5. End with what protects policyholders now. Say what should apply from day one of the transition, not at the end of it.

Five points worth arguing

  • Disclosure for every retail policy, not only cover above Rs 5 crore. A buyer of a Rs 5 lakh policy has the same information need as a buyer of a Rs 5 crore one.
  • Shorter deadlines for conduct rules. Suitability, seller tagging and clawback can apply immediately; expense caps may reasonably need time.
  • Pass-through. Ask for a commitment that lower distribution costs reach premium, and for disclosure of what was saved.
  • Renewal servicing. If renewals pay 5 percent, say what stops existing customers being neglected, and ask for a servicing standard alongside the cap.
  • Small-ticket cover. A floor or carve-out for two-wheeler and micro policies, or an explicit alternative, so rural and low-value cover keeps someone willing to sell and service it.

What happens next

IRDAI will weigh industry feedback against consumer submissions and publish what it decides. The cap levels are drafted and will probably move only a little. The timeline, the disclosure threshold and the treatment of renewals are the parts still genuinely open, which is exactly where individual comments carry weight. October 25, 2026 is the date; earlier in the window is better than the last day.