IRDAI · Essay № 16

Surrender value, lapsation, and the small print that keeps an industry profitable.

A reading of the 2024 IRDAI regulations on non-linked products, and the industry pushback that followed.

There is a particular kind of insurance contract that the industry has, for two decades, sold as a savings instrument and structured as an insurance instrument, and the difference between the two is most visible in what happens when the policyholder, two or three years in, decides to stop. The traditional non-linked life policy — endowment, money-back, par, non-par — has historically allowed the policyholder very little money back if he surrenders before maturity. The first year's premium, in most products, is treated as fully consumed. The second year is partial. By year three, the surrender value is non-zero but unflattering. By year five, the customer is closer to the door but still short of it.

In June 2024, the Insurance Regulatory and Development Authority of India issued the (Insurance Products) Regulations, 2024, which substantially rewrote the surrender-value formulas for non-linked individual savings products. The new regulations required that the special surrender value — the amount payable on surrender — be calculated on the basis of all premiums paid, with a more generous schedule from the second year onward. The change was numerically small. The industry's response was not.

The economics underneath

The industry's objection rested on a particular feature of how traditional policies are sold. A large fraction of the commission on a traditional policy is paid in the first year — sometimes a multiple of what is paid in subsequent years. The mathematics of this front-loading is sustainable only if a sufficient proportion of policies lapse, allowing the insurer to retain the unconsumed portion of those first-year premiums. The industry calls this lapsation income. The regulator, after 2024, calls it a transfer from short-stayers to long-stayers, and considered it inappropriate.

Lapsation income is the polite name for an industry's reliance on its customers' inattention.

The new surrender-value regime is, in regulatory terms, a small change with large consequences. A policy that previously returned twenty per cent of premiums on third-year surrender now returns substantially more. The insurer's economics have to be reworked. The commissions have to be restructured. The product design has to be reconsidered. The industry has, in the months since, been doing all of this, in slow stages, with frequent representations.

The harder question

The harder question is whether the regulator's change is enough. A surrender-value increase is a transfer from the persisting policyholder to the surrendering one, and the persisting policyholder is, in most products, the more loyal customer. There is a sense in which a fairer surrender regime makes the long-term policy less attractive — because the cross-subsidy that used to flow toward him is no longer there. The regulator has accepted this. The industry has accepted it more quietly. The customer, who is the one for whose benefit all of this is being done, has, as usual, not been consulted on his preferences.

Further reading

Three essays that follow on.

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