A legal notice has been issued seeking the immediate cancellation of the recently published Insurance Business Registration Fee (Amendment) Regulations, 2024, which substantially increased insurance company registration renewal fees. The notice also demands suspension of the enhanced fee collection process.
The notice was served on Monday (20 April) in the public interest by Supreme Court lawyer Tanay Kumar Saha. The respondents named include the Secretary of the Financial Institutions Division under the Finance Division and the Chairman of the Insurance Development and Regulatory Authority.
It requests that the implementation of the amended regulations be suspended within seven days. It further calls for insurance companies to be allowed to renew their licences in accordance with the 2018 regulatory framework. The notice warns that, failing compliance, a writ petition will be filed before the High Court Division under Article 102 of the Constitution of Bangladesh in the interest of public law enforcement.
According to the notice, under the 2018 gazette notification, the fee rate was set at BDT 1.00 per thousand of gross premium. However, the 2024 amended regulations have significantly increased the fee structure.
The notice highlights that, for a company with a gross premium of BDT 100 crore, the renewal fee has been raised from BDT 10 lakh to BDT 25 lakh under the revised framework. It further notes that the fee is projected to reach BDT 50 lakh by 2032. The notice describes this as an increase ranging from approximately 150 per cent to 500 per cent, and argues that such escalation is unreasonable and disproportionate.
It is also stated that several insurance companies have already fulfilled their legal obligations by paying fees under the previous regulatory regime before 30 November 2025. The notice contends that applying the amended rules in 2026 to transactions or obligations already settled under the earlier framework contradicts the established legal principle that new laws apply prospectively, not retrospectively.
Fee structure comparison
| Aspect | 2018 Regulation | 2024 Amendment | Stated Effect in Notice |
|---|---|---|---|
| Fee rate basis | BDT 1.00 per thousand gross premium | Revised upward significantly | Substantial increase in calculation |
| Example company (BDT 100 crore premium) | BDT 10 lakh | BDT 25 lakh | 150% increase alleged |
| Projected future fee (2032) | Not specified | BDT 50 lakh | Up to 500% increase alleged |
The notice further argues that the increased financial burden would reduce the surplus of insurance companies. It claims this could affect policyholders by lowering expected bonuses and reduce dividends for shareholders, potentially creating instability within the insurance sector.
Additionally, it is alleged that the regulatory authority’s administrative expenses are being transferred onto the public and insurance operators, which the notice describes as an improper financial burden. It asserts that such administrative costs should be borne by the Financial Institutions Division rather than being imposed on insurers.