**Executive Summary**
This circular, issued by the International Financial Services Centres Authority (IFSCA) on November 27, 2025, clarifies the rules regarding invoice raising by IFSC Insurance Offices (IIOs). It addresses operational constraints faced by IIOs transacting through IFSC Banking Units (IBUs), specifically concerning the currency of invoices for reinsurance contracts. The clarification is available on the IFSCA website (www.ifsca.gov.in).
**Key Points / Main Content**
* **Invoice Currency:**
* An IIO transacting reinsurance business may raise invoices on Indian insurers, foreign insurers, reinsurers, or cedants in the currency of the underlying reinsurance contract, including in INR.
* The realization of the amount against such invoice, in the bank account of the IIO, maintained with any IBU shall be in the specified foreign currencies.
* **Definition of Specified Foreign Currency:**
* "Specified Foreign Currency" refers to the currencies specified in the First Schedule of the International Financial Services Centres Authority (Banking) Regulations, 2020, as amended.
* **Authority:**
* This clarification is issued under sections 12 and 13 of the International Financial Services Centres Authority Act, 2019, read with regulation 18 of the International Financial Services Centres Authority (Registration of Insurance Business) Regulations, 2021.
**Impact Analysis**
**IFSC Insurance Offices (IIOs)**
* **Impact:** Clarification of permissible invoice currencies provides operational flexibility and reduces constraints faced when transacting reinsurance business through IFSC Banking Units (IBUs).
* **Action Required:** Ensure compliance with the clarified rules regarding invoice currency and realization of amounts in specified foreign currencies.
**Indian Insurers, Foreign Insurers, Reinsurers, Cedants**
* **Impact:** May receive invoices in INR or other currencies of the underlying contract, depending on the agreement with the IIO.
* **Action Required:** Be aware of the permissible invoice currencies and align internal processes accordingly.
**IFSC Banking Units (IBUs)**
* **Impact:** Will be responsible for handling the realization of invoice amounts in specified foreign currencies.
* **Action Required:** Ensure compliance with the requirement for realizing invoice amounts in specified foreign currencies.
Key Entities Referenced
International Financial Services Centres Authority (IFSCA): Authority responsible for regulating financial services in International Financial Services Centres in India.
International Financial Services Centres Authority Act, 2019: The Act which established the IFSCA.
International Financial Services Centres Authority (Registration of Insurance Business) Regulations, 2021: Regulations by IFSCA concerning the registration of insurance businesses.
IFSCA Insurance Offices ('IIOs'): Insurance offices operating within International Financial Services Centres and regulated by IFSCA.
International Financial Services Centres Authority (Banking) Regulations, 2020: Regulations pertaining to banking activities within International Financial Services Centres.
आनो भद्राः क्रतवो यन्तु ववश्वताः ।
CIRCULAR
eF.No. 103/IFSCA/Ins/CIRC/1/2021 November 27, 2025
To,
All IFSC Insurance Offices,
Subject: Clarification on raising of Invoice by IFSC Insurance Offices
Reference may be drawn to the International Financial Services Centres
Authority (Registration of Insurance Business) Regulations, 2021, in particular
regulation 18 which inter-alia empowers the International Financial Services
Centres Authority (herein after referred to as ‘IFSCA’) to issue clarification for
facilitating and regulating financial services related to insurance and re-insurance
in an International Financial Services Centre (IFSC).
2. IFSCA has received feedback and representations from IFSC Insurance Offices
(‘IIOs’) regarding certain operational constraints faced by them, on account of
raising of invoice in the currency of the underlying contract of reinsurance, while
transacting through the IFSC Banking Units (IBUs).
3. In this regard, it is hereby clarified as follows:-
“An IIO transacting re-insurance business may raise invoice on Indian insurer(s),
foreign insurer(s), re-insurer(s) or cedant(s) as the case may be, in the currency
of the underlying contract of reinsurance, including in INR:
However, the realization of amount against such invoice, in the bank account of
the IIO, maintained with any IBU shall be in the specified foreign currencies.
Page 1 of 2Explanation. - For removal of doubt, it is hereby clarified that "Specified Foreign
Currency" shall mean the currencies specified in the First Schedule of the
International Financial Services Centres Authority (Banking) Regulations, 2020,
as amended from time to time.
4. This clarification is issued in exercise of powers conferred under section 12 and
13 of the International Financial Services Centres Authority Act, 2019 read with
regulation 18 of the International Financial Services Centres Authority
(Registration of Insurance Business) Regulations, 2021.
5. A copy of this clarification is available on the website of IFSCA at
www.ifsca.gov.in
sd/-
Bhaskar Khadakbhavi
General Manager
Division of Insurance Regulations
bhaskar.khadakbhavi@ifsca.gov.in
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