India - Tier D · Elevated · Case: ICICI Lombard
Posted: Sun Oct 11, 2026 9:55 am
Fijishi Jurisdiction Index 2026 · Entry IN · Published 12 October 2026
At a glance
1. The rules in India
This edition found no AI-specific rule for insurers in India. The Insurance Regulatory and Development Authority of India (IRDAI) set up a working group on AI governance in the insurance sector on 17 June 2026; the order sets no expectations for insurers. The government's AI governance guidelines are voluntary.
IRDAI's Master Circular on health insurance (29 May 2024) is binding. It provides that no claim may be repudiated without the approval of a named committee, which is to decide independently on every repudiation. It does not mention AI.
Who these rules reach
This band describes how clearly the rules meet the AI use that ICICI Lombard has itself published. It is not a finding that ICICI Lombard has breached any rule.
Why ICICI Lombard: ICICI Lombard's own Integrated Annual Report 2025-26 says it deployed generative AI in health insurance claims.
The question
3. The same question for other firms in India
Any health insurer in India that uses AI in claims faces the same point: whether its Claims Review Committee is told when AI played a part in a claim it is asked to reject. This entry gives no band to any firm other than ICICI Lombard.
4. What this entry does not establish
Sources
None share a law or regulator with this entry.
________________________________________
Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry IN · Corrections: none.
At a glance
| Jurisdiction tier | Tier D - Not yet specified. No binding instrument that applies to insurers' own use of AI, and no issued regulator document addressed to this insurance market, sets out rules or expectations for AI. |
| Case examined | ICICI Lombard - generative AI in health insurance claims |
| Band for this case | Elevated |
| Rules reach | Insurers: directly · Reinsurers: not stated · Intermediaries: not stated |
| Last verified | [actual date of the launch-window check] |
This edition found no AI-specific rule for insurers in India. The Insurance Regulatory and Development Authority of India (IRDAI) set up a working group on AI governance in the insurance sector on 17 June 2026; the order sets no expectations for insurers. The government's AI governance guidelines are voluntary.
IRDAI's Master Circular on health insurance (29 May 2024) is binding. It provides that no claim may be repudiated without the approval of a named committee, which is to decide independently on every repudiation. It does not mention AI.
Who these rules reach
- Insurers: directly. The circular requires insurers to constitute a Claims Review Committee to "independently take final decision on repudiation of every claim" (Master Circular, pp. 25–26, under "Claims Handling and Settlement process", item b).
- Reinsurers: not stated.
- Intermediaries: not stated.
This band describes how clearly the rules meet the AI use that ICICI Lombard has itself published. It is not a finding that ICICI Lombard has breached any rule.
Why ICICI Lombard: ICICI Lombard's own Integrated Annual Report 2025-26 says it deployed generative AI in health insurance claims.
The question
In briefICICI Lombard's Integrated Annual Report 2025-26 says: "We deployed GenAI in health insurance claims and operations, streamlining processes and improving turnaround while maintaining human oversight." IRDAI's Master Circular on Health Insurance Business (IRDAI/HLT/CIR/PRO/84/5/2024, 29 May 2024) provides that no claim may be repudiated without the approval of the Product Management Committee or its three-member sub-group, the Claims Review Committee, which is to "independently take final decision on repudiation of every claim". When GenAI has been used in a health claim that ends in repudiation, does ICICI Lombard's Claims Review Committee see that AI was used and what it contributed, or does it review the claim file without that information?
Why this band: The question points to one firm and one named committee, but the binding rule it rests on does not name or cover AI.ICICI Lombard says it uses generative AI in health claims, with human oversight. An IRDAI rule requires a named committee to decide independently on every claim rejection. ICICI Lombard has not publicly said whether that committee is told when AI has played a part in a claim it is asked to reject.
3. The same question for other firms in India
Any health insurer in India that uses AI in claims faces the same point: whether its Claims Review Committee is told when AI played a part in a claim it is asked to reject. This entry gives no band to any firm other than ICICI Lombard.
4. What this entry does not establish
- The IRDAI circular to which the health circular defers for the detail of its claims provisions was not read.
- Whether any later IRDAI circular has replaced the 2024 health circular was not checked.
- What role AI plays in any repudiated claim. The question is conditional, and this entry says nothing either way.
- Overdue: the IRDAI working group's recommendations, due within three months of 17 June 2026.
Sources
- ICICI Lombard General Insurance Company Limited, Integrated Annual Report 2025-26 (no publication date printed; covers the year to 31 March 2026). Company's own. icicilombard.com PDF
- IRDAI, Master Circular on IRDAI (Insurance Products) Regulations 2024 – Health Insurance, IRDAI/HLT/CIR/PRO/84/5/2024, 29.05.2024 (printed). Regulator (binding). Cited without a link; the link was not confirmed.
- IRDAI, Office Order on the Working Group on AI Governance in the Insurance Sector, IRDAI/GA&HR/ORD/MISC/90/06/2026, 17th June, 2026 (printed). Regulator. irdai.gov.in
- Ministry of Electronics and Information Technology, India AI Governance Guidelines, "Enabling Safe and Trusted AI Innovation", November 2025 (no day printed). Government (voluntary). static.pib.gov.in PDF
None share a law or regulator with this entry.
________________________________________
Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry IN · Corrections: none.