Pre-issuance verification calls (PIVC): what IRDAI expects from insurers in 2026

What a pre-issuance verification call is, and why insurers make it

PIVC stands for pre-issuance verification call. The insurer calls the proposer, the person applying for the policy, after the proposal form is signed but before the policy is issued. The aim is to confirm that the person understood the product, the premium, who gets paid and their right to cancel, while there is still time to stop the sale.

Timing is what sets the PIVC apart from other calls. A welcome call or a post-sale feedback call happens after the policy is issued, when the contract already exists. The PIVC is the last chance to stop a wrong sale before there is a contract to unwind and a premium to refund.

PIVCs are most common in life insurance, especially savings, annuity and unit-linked plans sold through banks and telemarketers, where long premium terms and complex benefits make mis-selling most costly. IRDAI, India's insurance regulator, set out the purpose in a 2020 circular. It said the call is made "to prevent mis-selling and unfair business practices". It added that the call ensures prospects "are fully informed and made aware of the terms and conditions of the product being sold" (IRDAI circular of 12 May 2020).

Is a PIVC mandatory under IRDAI rules?

Not by name, as far as we found. We found no IRDAI regulation or circular now in force that says insurers must make a pre-issuance verification call, though we searched IRDAI's site rather than reading every circular. Even the 2020 circular, the only one on the subject, was permissive. It said life insurers "are encouraged to conduct Pre-Issuance Verification Call (PIVC) to the extent possible and certainly in important cases", and suggested board-approved guidelines to that effect (IRDAI/Life/Misc/CIR/116/05/2020).

The Master Circular on Protection of Policyholders' Interests, 2024 then repealed it, listing it as item 27 among the circulars it supersedes (para 31.1; IRDAI/PP&GR/CIR/MISC/117/9/2024, 5 September 2024). The 2017 policyholder regulations it relied on went too, repealed by regulation 58(1)(g) of the 2024 regulations.

What remains are general duties, and a PIVC is one of the clearest ways to show they were met. Under the IRDAI (Protection of Policyholders' Interests, Operations and Allied Matters of Insurers) Regulations, 2024, the sales process must be transparent and give the prospect "all necessary information" for an informed decision (regulation 6(b)). Product features must be "represented correctly and fully" (regulation 7(2)(i)), and insurers and distributors must follow IRDAI's guidance on mis-selling and suitability (regulation 21(7)).

Those three regulations are exactly the ones IRDAI used when it acted over a defective verification call in September 2026. The rules we found also say nothing about what happens when a proposer misses or declines the call; that is left to each insurer's own process.

What IRDAI found in the Canara HSBC Life order

The case concerned a deferred annuity that Canara HSBC Life sold, through its corporate agent Canara Bank, to an 88-year-old customer. The product allowed entry only from age 30 to 80. The premium was ₹2 lakh a year for four years, and the customer's daughter was the annuitant, the person who receives the annuity. IRDAI fined the insurer ₹1 crore under section 102 of the Insurance Act, 1938.

The order (Ref IRDAI/PP&GR/ORD/MISC/118/9/2026) is dated 10 September 2026, and the verification call is a large part of it. The caller said the annuity of ₹50,791 a year "will be given to you" ("aapko diya jayega"), when in fact it would go to the daughter. The insurer explained that "you" was only a way to personalise the call, and IRDAI rejected that explanation (para 5.10).

IRDAI then set out how it sees the call: "A pre-issuance verification call is a critical regulatory safeguard and a formal touchpoint for ensuring informed consent." In setting out the charges, the order also says the customer "was not adequately informed of premium payable and mode of payment" (para 3.2.3). The same paragraph notes an unverified second mobile number on the proposal form.

The call was not the only failure. IRDAI also cited the lack of any suitability or financial assessment and a benefit illustration with no verifiable acknowledgement. The Customer Information Sheet and a copy of the proposal form were not given to the customer, and premium was collected before issue.

According to the insurer's own submissions, after the case spread on social media it refunded the full premium of ₹4,09,000, reversed the commission and introduced "pre-issuance video-based validation calls" (para 4.7). IRDAI went further. Beyond the penalty, the order directs (in its words, "advises") the insurer to do two things relevant here, each within 90 days of the order:

• An audit of all policies sold through Canara Bank to proposers or policyholders above 75 in the three financial years ending 31 March 2026. By our count the report is due about 9 December 2026 (para 6.2.1).
• Stronger oversight of the insurer's corporate agents, with an Action Taken Report (para 6.2.2).

How ombudsmen and the 2011 guidelines judge call records

Judging a sale by its call is not new. Insurance ombudsmen, who hear policyholders' complaints against insurers, decide many mis-selling complaints on the verification call recording, and IRDAI's older guidelines on phone sales set out what that recording should contain.

• Use a standard script for each product, approved by the insurer's compliance officer (para 9.1).
• Give the caller's name and a choice of language, then continue only in the language the client picks (para 9.3(iii)).
• Tell the client the call is recorded and that they can have a voice copy at any time during the policy term or until a claim is settled (para 9.3(iv)).
• Send recordings of calls that lead to a policy to the insurer within 30 days of the sale (para 10(vii)).
• Keep a record of the whole process, from lead to sale, for six months beyond the policy term or until a claim is settled, whichever is later (para 12).
• Listen live to at least 1% of calls and have dedicated staff review the recordings of at least 3% of calls that lead to sales. Each month, make verification calls to at least 3% of distance-mode buyers. Keep life insurance verification call records for at least three years (para 13).
• In a dispute over the policy's wording, the client may give the call records and the key features document primacy over the policy wording (para 15).

What a PIVC should confirm

Put the order, the awards and the regulations together and a clear picture emerges of what the call has to cover. IRDAI has published no mandatory PIVC checklist that we found, so any list is a judgement about what the rules and rulings make important. The table maps each item to the rule or ruling behind it, and says plainly where an item is good practice rather than text.

The closest official model is the 2011 distance marketing guidelines, which ask for a yes or no, or understand or don't understand, answer against each item (para 9.5). That format is worth copying, because a recorded yes to a specific question is far easier to rely on later than a general "okay".

A sample PIVC script and the decision to issue

Turning that checklist into words is where most calls go wrong, as the Canara order shows. The outline below is an English sample built from the checklist, not an IRDAI text. It should be adapted to each product and approved by the insurer's compliance officer, as the 2011 guidelines ask. Run it in the customer's chosen language, one question at a time, with a clear yes or no recorded for each.

Because no rule now says which sales need a PIVC, the insurer has to decide, and a written, board-approved policy is the natural place to do it, as the 2020 circular suggested. Covering every savings, annuity and unit-linked sale is a sensible minimum. Keeping a version history of each script lets the insurer show later exactly which words a customer heard.

Before dialling, the same policy should require the checks that were missing in the Canara case. They are the product's entry age, the suitability assessment, and whether the phone number and email belong to the proposer rather than the agent. Customers above 75, or otherwise vulnerable, should be flagged for extra care.

The call should end in a real decision, not a formality. The chart after the script sets out a go or no-go test: any no, hesitation or confusion sends the case back before the policy is issued. For the opening line in other languages, see the recording-notice and AI disclosure scripts; the insurance renewal call script shows the same structure for a later stage of the policy.

• Open: "Hello, this is [name] calling from [insurer] about the life insurance proposal you signed on [date]. This call is recorded. Is this a good time to talk for about five minutes?"
• Identity and language: "Can you please confirm your full name and date of birth? Would you like to continue in English, or in another language?"
• Product: "You have applied for [product name], which is a life insurance policy. It is not a fixed deposit or a bank savings scheme. Is that your understanding?"
• Premium, term and payee: "Your premium is ₹[amount] every [year/month], payable for [n] years. The policy term is [n] years, and [benefit] will be paid to [named person], not to anyone else. Is that what you expected, and can you pay for the full period?"
• Illustration and risks: "Did you receive the benefit illustration? It shows that ₹[x] is guaranteed and ₹[y] depends on investment returns. If you stop paying, or if [proposer] dies before all premiums are paid, [what happens]. Is that clear?"
• Nominee, contact and promises: "Your nominee is [name, relationship]. Is the mobile number [xxxx] your own? Did anyone promise you any return, bonus, loan or refund that is not in these documents?"
• Free-look and close: "After you receive the policy, you have 30 days to read it and return it for a refund if you are not satisfied. Would you like us to go ahead and issue the policy?" If any answer is no or unsure, stop and refer the case back before issue.

Bank-sold policies, AI voice agents and calling numbers

Three practical questions come up once an insurer looks beyond the script. They are how the call fits with a partner bank's own checks, whether software can make it, and which number it should come from.

Key dates