Viksol Re IFSC Ltd., a reinsurance start-up promoted by a Singapore-based insurance group, commenced underwriting operations at GIFT City in November 2024 without obtaining registration from IFSCA, relying on its parent

CS Professional · IFSCA - Regulations, Listing and Compliances · PYQS · June 2026
Viksol Re IFSC Ltd., a reinsurance start-up promoted by a Singapore-based insurance group, commenced underwriting operations at GIFT City in November 2024 without obtaining registration from IFSCA, relying on its parent company's international standing as sufficient authorisation. Concurrently, Apex MGA Services IFSC, a Managing General Agent operating at GIFT City, entered into a binding authority arrangement with Hartwell Re, a foreign reinsurer based in Bermuda, enabling Hartwell Re to underwrite IFSC risks through Apex's platform. Neither Apex nor Hartwell Re had sought to determine whether their specific operational structure attracted any distinct registration obligation under the applicable IFSCA framework. When IFSCA's regulatory oversight division conducted a market inspection in January 2025, it flagged Viksol Re's unauthorised commencement of business and simultaneously questioned whether Apex MGA's arrangement with Hartwell Re had been structured and registered in compliance with the schedule governing such relationships. Both entities reached out to you, as you are a practising Company Secretary specialising in IFSC regulatory matters. In this backdrop, advise Viksol Re and Apex-Hartwell on the applicable registration obligations.

Answer & Explanation:

To ensure that only qualified and properly supervised entities operate within the IFSC, the IFSCA requires all insurance and reinsurance providers to obtain formal registration before commencing business. Requirement of Registration for Setting up of a IFSC Insurance Office as per Regulation 4 of the IFSCA (Registration of Insurance Business) Regulations, 2021 No person or entity may commence the business of insurance or reinsurance in the IFSC unless they have obtained registration from the IFSCA in accordance with the provisions of the IFSCA (Registration of Insurance Business) Regulations, 2021. This ensures that all participants meet minimum standards of financial soundness, governance, and operational capability. Application for Registration An applicant including Lloyd's seeking registration must make an application in the forms as specified by the IFSCA. These forms outline the information, documents, and declarations required for assessment by the IFSCA. Explanation: All regulatory provisions concerning: Lloyd's; Lloyd's IFSC; Registration of a Service Company of Lloyd's IFSC are specified in the Second Schedule of IFSCA (Registration of Insurance Business) Regulations, 2021. This includes eligibility criteria, operational requirements, reporting obligations, and governance standards specific to the Lloyd's market structure. Provisions Related to Managing General Agents (MGAs), relevant Foreign Insurers or Re-insurer and its registration are specified in Third Schedule of IFSCA (Registration of Insurance Business) Regulations, 2021. These provisions govern the conditions under which such entities may operate through MGAs within the IFSC framework. Both entities i.e Viksol Re and Apex MGA Services IFSC, are in regulatory default. Viksol Re must immediately cease operations and apply for a fresh registration; their "unauthorized commencement" may lead to heavy penalties and blacklisting of the promoters. Regarding the Apex-Hartwell arrangement, the binding authority is invalid until both the MGA (Apex) and the Foreign Reinsurer (Hartwell) are registered under the Third Schedule. Being a Practicing Company Secretary, it is advised to suspend the arrangement and file the prescribed forms to IFSCA to regularize their status before further risks are underwritten.

Topics: IFSC Regulations

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