IRDAI’s 2025 maintenance regulations keep every record at least ten years from the last transaction or policy expiry, and claims documents on a slab that reaches twelve years for the largest claims. The DPDP Act gives the policyholder — and, after death, the nominee — a right to erasure over exactly those records. The correct answer to most erasure requests an insurer will receive is a lawful partial refusal, and the refusal must itself be evidenced, record by record, with a diary date. That workflow exists nowhere in the sector’s tooling today.
FROM THE SEPTEMBER 2026 PROBLEM REGISTER · 10 PROBLEMS SWEPT · 4 SHOWN HERE · HOW THIS WAS BUILT
Each of these is marked confirmed: two independent sources, at least one the instrument itself or a practitioner record — here including a public procurement document and a published regulatory order.
DPDP s.8(7) and Rule 8 meet the IRDAI (Maintenance of Information by the Regulated Entities and Sharing of Information by the Authority) Regulations, 2025: Regulation 16 keeps records a minimum of ten years from the last transaction or policy expiry; Schedule I clause 8 keeps claims documents three, five, seven or twelve years from settlement, by claim size. In July 2026 India’s largest insurer issued a public RFP to procure “Data Principal Rights Management” and eleven other DPDP modules — ten months before the May 2027 date.
SOURCES · IRDAI Maintenance of Information Regulations, 2025 (instrument, clause-read) · LIC RFP, 13 Jul 2026 — DPDPA tools (public procurement document)
Confirmed · sweep of 2 Sep 2026Section 6(1) requires consent that is free, specific, informed, unconditional and unambiguous, limited to the specified purpose; Rule 3 requires an itemised notice. DPDP’s only non-consent bases are the s.7 legitimate uses, and contractual necessity is not among them — so historical health data cannot be re-based for automated underwriting or renewal pricing the way GDPR allows. This touches the first document of every sale.
SOURCES · DPDP Act s.6, s.7 (statute) · LIC RFP (practitioner — consent management and notice management procured as new capabilities) · Tuli & Co on the Rules and the insurance sector (context)
Confirmed · the largest process change DPDP forces on insurersDPDP s.14 lets a nominee exercise the deceased’s rights. IRDAI Schedule I clause 8 keeps claims of twenty lakh rupees and above — most modern term-policy death claims — for twelve years from settlement. The nominee-initiated erasure must be partially refused for over a decade, while the insurer simultaneously owes the nominee’s own personal data the full fiduciary duty: a second data principal inside the same record. Erasing evidence needed in a repudiation dispute and refusing without a lawful basis are both high-consequence errors.
SOURCES · DPDP Act s.14, s.12 (statute) · IRDAI 2025 Regulations, Schedule I cl. 8 (instrument) · Interplay between insurance and data protection (context)
Confirmed · the sharpest rights request an insurer receivesSection 8(1) makes the fiduciary responsible for processing on its behalf and s.6(10) puts the burden of proving consent on it. Life insurance alone works through roughly thirty-three lakh individual agents. In 2025 an IRDAI order against a web aggregator recorded around a hundred thousand telemarketing-led policies whose call recordings were incomplete or unavailable — the consent-evidence failure DPDP will make decisive. Digital point-of-sale journeys address new business; nothing addresses the data agents already hold.
SOURCES · DPDP Act s.8(1), s.6(10) (statute) · IRDAI order, Aug 2025, as reported (enforcement record) · Life Insurance Council agent count (practitioner)
Confirmed · a scale collision on the least-instrumented channelInsurance was the sector where the AI research drafts were most wrong on retention. The register read the 2025 regulations at clause level and replaced every stale figure.
Schedule I clause 8 of the 2025 regulations is a slab: three years below one lakh, five to ten lakh, seven to twenty lakh, and twelve years at twenty lakh and above — all from settlement. “Seven years” is true for one slab only.
Regulation 16: a minimum of ten years from the last transaction or policy expiry, longer where another law requires it. No “plus five” rule exists in the current instrument.
Regulation 18(i) of the 2025 regulations repealed the 2015, 2020 and 2012 instruments. Any material citing the 2015 regulations as the retention source is stale. Their one surviving contribution — records of Indian policies and claims held in data centres in India only — now lives at Regulation 9(iii).
Section 15 sets out data principals’ duties. A nominee acting after death or incapacity is a rights-agent under s.14 — not an heir, and not the same thing as a nominee under the policy.
Section 5(2) allows continued processing of pre-Act consented data. The real obligations are the notice owed to every legacy policyholder “as soon as reasonably practicable” and the s.6(10) burden of proof — a notice-delivery and evidence problem across long-tenure books whose contact details the policy has outlived, not wholesale re-consenting. No insurer has been designated a Significant Data Fiduciary, and no DPDP penalty can be imposed on anyone before mid-May 2027; the schedule is stated plainly here, once.
RULES NOTIFIED MID-NOV 2025 · CONSENT-MANAGER REGISTRATION OPENS MID-NOV 2026 · DUTIES, RIGHTS AND PENALTIES MID-MAY 2027 · DATES STATED AS THE NOTIFICATIONS STATE THEM
Everything below is live today and maps to shipped code — the same rule as every page on this site. Capabilities we are still building are not listed here.
Every access, correction and erasure request carries a response deadline computed when it is filed and an escalation ladder when it slips. An erasure cannot be marked complete unless its execution path is configured, and the destruction is recorded, not asserted. The written refusal for a record IRDAI holds for twelve years lands in the same audit chain, dated and attributable — the diary entry the regulator can read.
Live: DSR orchestration · SLA tracking · grievance workflowsUnderwriting, claims, analytics and marketing become separate, specified purposes with separate decisions; nothing is pre-ticked. Notices are versioned so a change forces re-consent and the old version stays on record. Withdrawal is as easy as the grant. Each decision produces a receipt the policyholder can keep and anyone can verify.
Live: purpose-by-purpose consent · versioned notices · PDF receiptsNotices and consent flows are rendered in the twenty-two languages of the Eighth Schedule by a self-hosted translation model — no third-party API. For the paper-and-agent channel in collision 04, this page does not claim a capture tool: what is live is consent evidence for the digital journey. We would rather say that than imply the agent’s folder is covered.
Live: notices & consent flows in 22 Indian languagesEvery consent, erasure, refusal and notice publication is a linked record bound to the one before it, and the chain is periodically stamped by an independent timestamp authority. When the s.6(10) burden falls on you, you produce a receipt that verifies in a browser, not a database row. Anyone can check it.
Live: tamper-evident audit trail · independent anchoring · verifiable receipts