File and Use vs Use and File: Product Approval
Who signs off a new general insurance product now, and what changed from the regime the courseware describes.
Before a general insurer can sell a new fire, motor or liability product in India, it has to be approved and given a Unique Identification Number (UIN). The question is who approves it, and when. Under File and Use, the insurer files with IRDAI first and markets only after that. Under Use and File, the insurer's own committee approves the product, it gets a UIN and goes on sale without prior filing with IRDAI.
Since IRDAI's Insurance Products Regulations 2024 came into force on 1 April 2024, general insurance has moved firmly to Use and File, with the insurer's board and its Product Management Committee answerable for every product. Older study material, including parts of the courseware, still describes the earlier File and Use process.
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File and Use vs Use and File
Definition (2024 regulations)
File and Use
Product may be marketed only after prior filing to IRDAI and assignment of a UIN
Use and File
Product may be launched after a UIN is assigned, without prior filing to IRDAI
Who approves before launch
File and Use
IRDAI reviews the filing
Use and File
The insurer's Product Management Committee
Role of the PMC
File and Use
Recommends the product for filing
Use and File
Approves the product
Speed to market
File and Use
Slower, waits on the regulator
Use and File
Faster; IRDAI's stated aim is quicker response to market needs
Where it applies in general insurance now
File and Use
Kept in the regulations as a defined route
Use and File
The general insurance master circular frames product approval around Use and File
| Point | File and Use | Use and File |
|---|---|---|
| Definition (2024 regulations) | Product may be marketed only after prior filing to IRDAI and assignment of a UIN | Product may be launched after a UIN is assigned, without prior filing to IRDAI |
| Who approves before launch | IRDAI reviews the filing | The insurer's Product Management Committee |
| Role of the PMC | Recommends the product for filing | Approves the product |
| Speed to market | Slower, waits on the regulator | Faster; IRDAI's stated aim is quicker response to market needs |
| Where it applies in general insurance now | Kept in the regulations as a defined route | The general insurance master circular frames product approval around Use and File |
How a General Insurance Product Gets to Market Today
- 1
Design and price
The product must cover an insurable risk with real risk transfer, be simple and transparent, follow the basic principles of insurance, and carry rates that are not excessive, inadequate or unfairly discriminatory.
- 2
Product Management Committee approval
A board-constituted committee (chief underwriting officer, appointed actuary, distribution, investment, technology and compliance heads) checks design, pricing, compliance and product risks such as capital, reinsurance and profitability, and records its sign-off.
- 3
UIN assigned
A product or add-on can be sold only after a UIN is assigned. The UIN is quoted on every policy document, sales leaflet and return.
- 4
Documentation and certification
The PMC makes sure the Use and File documentation is complete, and the insurer submits a certificate signed by the CEO.
- 5
Publish retail wordings
For retail products, the wordings, documents and sales literature go on the insurer's website before launch or within seven days of the UIN, whichever is earlier.
- 6
Review every year
The appointed actuary reviews every product on sale at least once a year and reports to the PMC, which can modify or withdraw it.
Reading a UIN
IRDAI's own example from the 2024 master circular: IRDAN000RPMT0076V01202324.
- IRDA + N
- Standard prefix; N stands for non-life.
- 000
- The general insurer's registration number.
- R
- Product type: R retail, C commercial, O others.
- P
- Filing type: P main product, A add-on.
- MT
- Line of business: here motor. Others include PR property, MR marine, EN engineering, LB liability.
- 0076, V01, 202324
- Sequence number, version 01, and the financial year of launch (2023-24).
Quick practice on risk inspection and hazards. No signup.
Where the Courseware May Differ
The 2016 guidelines on product filing for general insurance, the 2022 product filing circular and the March 2023 Use and File circular were all repealed by IRDAI's 2024 master circular on general insurance business. Questions built on the older File and Use timelines describe that earlier regime. Two rules carried over: a change to the scope of cover, the limit of liability or the basis of cover makes it a new product needing a new UIN, and insurers may not withdraw or refuse to offer the old tariff products that existed before the master circular.
How IC-11 Tests This
Expect the definitions (which procedure needs prior filing), who certifies or approves (appointed actuary and PMC), and what a UIN is. The trap is reversing the two names: File and Use means file first, Use and File means use first. Another is treating a minor wording edit and a change in scope of cover alike; only the second makes it a new product.
FAQs
What is the difference between File and Use and Use and File?expand_more
Under File and Use the insurer files the product with IRDAI and sells only after that and a UIN. Under Use and File the insurer's Product Management Committee approves it, a UIN is assigned, and it goes on sale without prior filing.
What is a UIN in general insurance?expand_more
The Unique Identification Number every general insurance product and add-on must carry. It encodes the insurer, retail or commercial type, main product or add-on, line of business, version and year of launch.
Who approves a new general insurance product in India?expand_more
Under the 2024 framework, the insurer's board-constituted Product Management Committee, which must include the appointed actuary. IRDAI can still direct an insurer to withdraw a product that is not in policyholders' interest.
Which regulations govern insurance product approval now?expand_more
The IRDAI (Insurance Products) Regulations 2024, read with IRDAI's 2024 master circular on general insurance business for non-life products.
Next steps
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