サマリー：インドの損害保険会社が直面する4つの変化

本稿は、インドの民間損害保険会社（単体の医療保険会社を含む）の2022年度から2025年度までの年次報告書において開示された課題を要約したものです。（ここで2022年度は2021年4月から2022年3月までを指します。）この期間、開示内容全体を通じて4つの変化が見て取れます。第1に、COVID-19は、2023年度以降、主要リスクとして言及される頻度が低下しており、これに加えて、業務面での準備態勢の改善や、パンデミック対応から得た教訓に関する記述が見られます。第2に、保険金支払コストのインフレ、特に医療インフレが、収益性に関する議論においてより大きく取り上げられるようになっており、医療提供者の価格設定、利用動向の変化、コンバインド・レシオへの圧力と頻繁に関連付けられています。第3に、規制面の動向（事業費や販売経路の経済性に影響を及ぼす変更、およびより広範な「Insurance for All by 2047（2047年までにすべての人に保険を）」というビジョンを含む）は、背景事情というよりも、実行上の要件として位置付けられる傾向が強まっています。第4に、自然災害および気候関連リスクがより重視されるようになっており、洪水やサイクロンの影響、農作物の変動性、ならびにモデリングや再保険戦略の改善の必要性について言及されることが多くなっています。

デジタルトランスフォーメーションは一貫したテーマとなっており、その位置付けは、COVID-19下で事業継続を可能にする手段から、基本能力へと変化しています。その中で、差別化要因は、データ、自動化、リスク選択の観点から説明されています。保険会社が掲げる優先事項では、分析主導の引受査定、より自動化された保険金支払業務、規律ある事業費管理など、再現可能な能力がますます重視されています。本稿の知見は、開示された記述に基づくものであり、したがって、リスクの大きさを定量的に評価したものではなく、方向性を示すものです。

Summary: Four shifts facing India’s general insurers

This paper summarises challenges described in annual report disclosures of India’s private-sector general insurers, including standalone health insurers, from FY2022 to FY2025 (FY = financial year; FY2022 is April 2021 to March 2022). Over this period, four shifts are apparent across the disclosures. First, COVID-19 is referenced less frequently as a primary risk after FY2023, alongside commentary on improved operational readiness and pandemic-response learnings. Second, claims-cost inflation—medical inflation in particular—features more prominently in profitability discussions, often linked to provider pricing, utilisation changes and pressure on combined ratios. Third, regulatory developments (including changes affecting management expenses and distribution economics, and the broader “Insurance for All by 2047” vision) are increasingly framed as execution requirements rather than background context. Fourth, catastrophe and climate-related risks receive greater emphasis, with more frequent references to flood and cyclone impacts, crop volatility and the need for improved modelling and reinsurance strategy.

Digital transformation is a consistent theme, with the framing evolving from enabling continuity during COVID-19 to a baseline capability, where differentiation is described in terms of data, automation and risk selection. Insurers’ stated priorities increasingly emphasise repeatable capabilities, including analytics-led underwriting, more automated claims operations and disciplined expense management. Findings reflect disclosed narratives and are therefore directional rather than a quantified assessment of risk magnitude.

Scope and approach: Our analysis of the annual reports of India general insurers

This analysis is based on a review of insurers’ annual report disclosures for four financial years (FY2022–FY2025). The focus is on private-sector general insurers, including standalone health insurers, and on how they described (i) key external and operating challenges and (ii) management’s outlook and stated strategic priorities. Issues were analysed across years to assess whether they appeared to be resolving, persisting or emerging. Where available, observations are synthesised at an industry level rather than attributing detailed statements to individual insurers.

AI tools were used to support document summarisation and extraction, with outputs reviewed and curated for consistency. As with any disclosure-based review, findings reflect the commentary that companies chose to report and how they framed these topics each year. AI outputs were used for drafting support only.

How disclosed priorities shifted from FY2022 to FY2025 for insurers in India

Figure 1 summarises the seven priorities that recur across insurers’ disclosures, and tracks how their relative prominence changed from FY2022 to FY2025 using qualitative status labels. Each cell in the figure uses a qualitative label to reflect prominence in annual report disclosures for that year; labels may indicate level (e.g., Limited/Emerging through High/Critical/Very Intense) and, where relevant, direction of change (e.g., Declining, Stabilised). Labels are directional and are not a quantified score. The intent is to illustrate the industry’s shift from pandemic-driven volatility to a multi-factor risk environment where claims inflation, competition, regulation and climate risk are simultaneously in focus.

*Notes and references for Figure 1:
1. These labels are author-applied qualitative tags based on frequency/strength of language in disclosures.
2. FY = financial year; FY2022 is April 2021 to March 2022; FY2023 is April 2022 to March 2023; FY2024 is April 2023 to March 2024; FY2025 is April 2024 to March 2025

Sources:
1. Annual Reports of 24 insurers comprising all private-sector general insurers and standalone health insurers for four consecutive years FY2022–FY2025 (author synthesis).
2. IRDAI Expenses of Management (EOM) Regulations, 2023
https://www.gicouncil.in/news-media/gic-in-the-news/synopsis-of-irdai-expenses-of-management-eom-regulations-2023/
3. IRDAI Press Note on Vision Meet on “Insurance for All” by 2047 on August 23rd and 24th, 2024
https://irdai.gov.in/documents/37343/366347/Press+Note+for+Insurance+for+All+Meet.pdf/22e16806-d631-60fa-8e68-52cbd3ab9467?version=1.0&t=1724582104524&download=true
4. Sabka Bima Sabki Raksha (Amendment of Insurance Laws) Bill, 2025 passed by Parliament
https://www.pib.gov.in/PressReleasePage.aspx?PRID=2206011®=3&lang=1

Between FY2022 and FY2024, the private-sector general insurance industry in India experienced a significant shift in strategic focus. Initially, COVID-19 was identified as a key risk, but its prominence declined steadily until it featured only minimally in industry disclosures by FY2024. In its place, sustained challenges, such as medical inflation and heightened competition, emerged as principal structural impediments to profitability. During this time, discussions about climate and natural catastrophe (NatCat) risks became more frequent and detailed. Regulatory changes, especially in expense management and market expansion, grew in importance for strategic planning. Digital transformation shifted focus from operational continuity to analytics, automation and personalised products and services.

Which issues facing India’s general insurers are resolving–and which are persisting?

Figure 2 groups issues into three broad patterns based on FY2022–FY2025 disclosures. Some challenges appear time-bound (e.g., COVID-19), whereas others are capability shifts (e.g., digital transformation moving from urgency to business-as-usual). Several issues remain structural—not “solved,” but managed through ongoing underwriting, pricing, claims and portfolio actions. These distinctions are important when interpreting year-to-year messaging and setting expectations for future performance.

Source: Annual Reports of 24 insurers comprising all private-sector general insurers and standalone health insurers for four consecutive years FY2022–FY2025 (author synthesis).

Note: “Issue theme” reflects a consolidated topic repeatedly cited in FY2022–FY2025 annual-report disclosures (and aligned to the issue list in Figure 1); it is not intended as a formal risk taxonomy. Pattern classification consolidates issues into three groups: (1) Resolved (time-bound shock), (2) Capability shift (matured to business-as-usual) and (3) Structural/persistent pressure.

Implications for general insurance management teams: Key shifts from COVID-19 to structural pressures

The industry’s disclosures from FY2022–FY2025 reveal a shift from pandemic-driven instability toward an emphasis on balancing growth with profitability amid several simultaneous challenges. Medical inflation and competitive pricing within the sector are prompting a renewed focus on portfolio quality, stricter underwriting practices, tighter controls to limit claims leakage and better management of provider relations and networks. Climate risks and catastrophic events are increasingly highlighting the need for accurate exposure data, sophisticated event analysis and more efficient reinsurance strategies.

Additionally, evolving regulations—such as those concerning expense control and broader market development objectives—are reinforcing the need for disciplined operational approaches and scalable distribution models. Digital technologies have become essential; insurers that successfully leverage automation and data analytics will be best equipped to deliver superior risk selection, improve customer satisfaction and advance unit economics. Although these issues are visible across the market, their practical impact differs by business mix. Standalone health insurers tend to emphasise medical inflation, provider negotiations and care management; multi-line general insurers more frequently reference catastrophe exposure, motor claims inflation and the complexity of managing diversified portfolios.

The key shifts are outlined as follows:

• Climate and catastrophe risk: As COVID-19-related volatility recedes, insurers must prioritise climate and catastrophe risk management, including stronger exposure data and event analytics, as these topics are increasingly cited across industry disclosures.
• Digital transformation: Digital capabilities are now foundational. Management should focus on leveraging AI and personalisation to achieve differentiation, as digital transformation is considered the baseline rather than a competitive advantage.
• Regulatory alignment: Companies need to align strategies with evolving regulatory frameworks, such as IRDAI’s “Insurance for All by 2047” vision and increased Foreign Direct Investment (FDI) limits, to support market development and liberalisation.
• Claims-cost inflation: Persistent medical and claims inflation requires robust mitigation strategies, including stricter underwriting, refined pricing and enhanced provider/network management.
• Specialisation vs. diversification: Management must decide between pursuing depth (wellness ecosystems for standalone health insurers) or breadth (cross-selling for multi-line insurers), with digital-first players focusing on simplification.
• Profitability improvements: Although many companies report improved combined ratios and reduced losses, results vary by business line. Disclosures suggest an increasing emphasis on sustainable profitability through disciplined portfolio management and tailored strategies.

Together, these shifts underscore the need for management teams to balance growth and profitability, strengthen risk management, adapt to regulatory changes and advance digital and data-driven capabilities to remain resilient and competitive in a rapidly evolving insurance landscape.

Emerging issues for India’s general insurers for FY2026 and beyond

This section highlights issues that are likely to become more prominent in FY2026 and beyond, based on the direction of FY2022–FY2025 disclosures and broader themes commonly discussed in the market. As FY2026 annual reports are not yet available, these points should be treated as directional hypotheses rather than conclusions. Together, they imply increasing pressure on insurers’ transformation agendas to simultaneously address profitability, resilience and sustainable growth.

• Health affordability and product redesign: Continued medical inflation may accelerate benefit rationalisation, tighter underwriting at older ages, deeper use of care pathways and greater emphasis on preventative and wellness-linked propositions. These trends reinforce the need for stronger health cost management, provider strategy and product redesign capabilities—particularly for standalone health insurers—covering provider network design, tariff benchmarking, care management rules (pre‑authorisation, pathways) and affordability-focused product innovation whilst maintaining risk selection discipline.
• Catastrophe risk analytics and climate adaptation: Expect increased use of granular exposure data, vendor catastrophe models, scenario testing and event response playbooks, alongside more active reinsurance optimisation and portfolio steering. This translates into heightened focus on climate and NatCat exposure management, including accumulation monitoring, reinsurance structure optimisation and post‑event performance reviews.
• Motor insurance transformation: Telematics and usage‑based products may expand beyond pilots, whereas claims severity management (parts, labour, fraud) and repair‑network leverage will remain critical as vehicle technology evolves (e.g., EV‑related repair costs). These developments place greater emphasis on claims diagnostics, pricing adequacy reviews, portfolio remediation actions and stronger claims governance supported by fraud, waste and abuse analytics.
• Distribution economics and expense discipline: As insurers adapt to changes in management expense regulations, they may revise channel strategies, incentive structures and operating models to maintain unit economics whilst pursuing growth. This implies deeper channel profitability analysis, incentive redesign, operating‑model simplification and tighter linkage between expense discipline and measurable service and claims outcomes.
• Cyber-risk and operational resilience: As digital operations deepen, cybersecurity, third-party risk management and business continuity are likely to become more explicit board-level topics, with implications for both underwriting (cyber products) and internal controls. This reinforces the importance of enterprise risk management, stress and scenario testing beyond pandemic risk (e.g., NatCat, inflation, reserving), cyber resilience and third-party risk oversight.
• Underwriting and portfolio steering: Heightened volatility and margin pressure are likely to sharpen focus on underwriting authority frameworks, segment-level profitability measurement, risk appetite calibration and line-of-business strategy to balance growth ambitions with combined ratio performance.
• Data, analytics and AI-enabled operations (with governance): Increasing complexity across underwriting, claims and distribution underscores the need for robust analytics roadmaps, automation and triage design with clear benefits tracking and stronger model risk management, including documentation, monitoring and controls.
• Regulatory readiness and reporting effectiveness: Evolving regulatory expectations may require more structured impact assessments and strengthened management information to better connect disclosures with execution progress and measurable outcomes.
• Inclusion at scale: Meeting “Insurance for All” ambitions may push innovation in low-ticket, high-volume products. Partnerships (platforms, ecosystems, embedded insurance) and simpler, faster claims processes will be critical to sustaining trust, retention and long-term viability at scale.
• Fraud risk rising from Gen-AI: Generative AI has dramatically lowered the barrier for creating realistic fake photos and supporting documents, leading to a surge in fraudulent activity. Ultimately, as generative AI technology continues to evolve, ongoing investment in detection capabilities will be essential for insurers to defend against this new era of deception.

Conclusion: For India’s general insurers, the post-COVID era has not meant a return to normal

Annual report disclosures across FY2022–FY2025 show that COVID-19 has receded as a defining constraint for India’s private-sector general insurers (including standalone health insurers), but it has not been replaced by a “return to normal.” Instead, insurers are managing a tighter, faster-moving risk and economics environment—medical and claims-cost inflation,¹ intensified competition, evolving regulation and more visible climate and NatCat exposure—whilst analytics and AI are becoming foundational to decision-making.²

For management teams, the message is less about responding to a single shock and more about continuing to build repeatable capabilities that can keep pace with volatility—by linking pricing, claims, capital and reinsurance decisions to a clearer view of risk and unit economics. Insurers that steadily embed analytics and fit-for-purpose governance into day-to-day decision-making may be better placed to protect profitability whilst pursuing growth. For situations in which it would be helpful, Milliman can act as a thought partner—bringing actuarial insight and analytics experience to support evidence-based choices and implementation in ways that align with each insurer’s strategy, business mix and operating model.

¹ For more on medical inflation, see Buckle, J., Aggarwal, R., & Arora, H. (2026, April 8). Measuring medical inflation in India. Milliman. Retrieved May 7, 2026, from https://www.milliman.com/en/insight/measuring-medical-inflation-in-india.

² For more on claim automation, see Nazki, N., & John, M. Reimagining health claims through automation: Advancing claims efficiency in India’s insurance ecosystem. Milliman. Retrieved May 7, 2026, from https://www.milliman.com/en/insight/automation-advancing-claims-efficiency-india-insurance-ecosystem.