COMPARING LIFE INSURANCE LAWS ACROSS JURISDICTIONS
AUTHOR – RUSHIKESH PATIL, LLM SCHOLAR AT SHRI NAVALMAL FIRODIA LAW COLLEGE, PUNE
BEST CITATION – RUSHIKESH PATIL, COMPARING LIFE INSURANCE LAWS ACROSS JURISDICTIONS, ILE MULTIDISCIPLINARY JOURNAL, 4 (1) OF 2025, PG. 11-19, APIS – 3920-0007 | ISSN – 2583-7230.
Abstract
Life insurance plays a crucial role in financial security, with regulatory frameworks differing across jurisdictions. This study compares life insurance regulations, taxation policies, consumer protections, and market structures in India, the UK, the USA, Singapore, and Australia, identifying best practices that could strengthen India’s sector. The global life insurance market is expanding, with revenues projected to increase from USD 1,052,611.0 million in 2020 to USD 1,623,762.0 million by 2027. Among the largest insurers, the USA and China dominate, while the Life Insurance Corporation of India ranks 16th globally. Tax policies significantly impact affordability. India levies an 18% Goods and Services Tax (GST) on premiums, whereas the UK, Singapore, and Australia exempt life insurance from indirect taxation. In the USA, state-level premium taxes remain comparatively lower. While India provides tax deductions on premiums under Section 80C, other countries offer indirect benefits through financial structures. Regulatory bodies such as India’s IRDAI, the UK’s FCA, the USA’s NAIC, Singapore’s MAS, and Australia’s APRA oversee industry stability and policyholder protection. Legislative frameworks like the Insurance Act, 1938 (India) and the Life Insurance Act, 1995 (Australia) shape sectoral regulations. Consumer protection measures ensure trust. India’s Bima Bharosa Portal, the UK’s Financial Ombudsman Service, Singapore’s FIDReC, and Australia’s AFCA address grievances. Most countries offer a cooling-off period of 15 to 30 days for policy cancellation without penalties. This analysis highlights the need for India to refine regulations and taxation to enhance affordability while ensuring consumer protection. Adopting global best practices can create a more inclusive, resilient, and consumer-friendly insurance framework, fostering financial security for Indian citizens.
Keywords: Consumer protection, Cooling-off period, Global insurance market, Insurance regulations, Life insurance, Regulatory frameworks, Tax deduction