IRDAI Strengthens Oversight of Insurance Repositories with Revised Audit Guidelines

In a significant development aimed at streamlining investor protection processes, the Investor Education and Protection Fund Authority (IEPFA) under the Ministry of Corporate Affairs has issued a public notice dated 31st July 2025, reiterating the mandatory filing of Form IEPF-1A along with the prescribed Excel template. This compliance falls under Rule 5(4A) of the IEPF (Accounting, Audit, Transfer and Refund) Rules, 2016, and the final deadline for submission is 30th August 2025.

Background: Understanding Rule 5(4A)

The directive is based on amendments notified via G.S.R. 571(E) on 14th August 2019, effective from 20th August 2019. According to Rule 5(4A), any company that had transferred amounts under clauses (a) to (d) of Section 205C of the Companies Act, 1956 or under clauses (a) to (n) of Section 125(2) of the Companies Act, 2013, but failed to file the required statement—or filed it in a format other than the mandated Excel template—is required to file Form IEPF-1A using the prescribed format.

This applies particularly to those companies that either:

Transferred applicable amounts to the IEPF/Central Government without submitting the corresponding statement in Excel format, or

Filed Form IEPF-1 in any other format after the amended rule came into effect.

Compliance Status: Over 3,000 Companies Non-Compliant

Despite multiple reminders and more than ample time provided, the Authority reports that over 3,000 companies (including 1,758 listed and 1,103 unlisted firms) have failed to submit Form IEPF-1A in the required Excel format. Moreover, the Authority holds more than 31,000 Service Request Numbers (SRNs) filed under IEPF-1 or IEPF-7 using non-compliant formats.

This creates significant administrative challenges, particularly in identifying rightful investor claims, which can lead to short payments and delays in refunds — ultimately causing investor dissatisfaction and complaints.

Transition to MCA21 V3 and Final Opportunity

To aid in rectifying the backlog and ensuring smoother disbursal of investor claims, the IEPFA has transitioned to the new MCA21 Version 3 portal. Companies that have not yet complied are now given a final window of 30 days (up to 30th August 2025) to file Form IEPF-1A in the prescribed format.

The Authority will share the list of relevant SRNs and the appropriate Excel templates directly with each company’s Nodal Officer via their registered email IDs, simplifying the process and removing ambiguity.

Consequences of Non-Compliance

Failure to comply with this directive by the deadline will invite regulatory action under the Companies Act, 2013. The IEPFA has made it clear that no further extensions will be granted, and companies must treat this as the final compliance notice.

RECENT UPDATES