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IMF Compliance Retainer Services

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Half-Yearly IRDAI Returns: Period ends 31 March (H2) and 30 September (H1); filing within 30 days through IRDAI portal. Business volumes, insurer-wise breakup, ISP performance, premium handling, Code of Conduct compliance.

Statutory Audit + ITR-6 + ROC: Statutory audit under Section 139, ITR-6 by 31 October, ROC trio AOC-4 (30 days), MGT-7 (60 days), ADT-1 (15 days), DIR-3 KYC by 30 September, DPT-3 annual.

ISP Renewal + Inspection Support: ISMP and Principal Officer renewal, ISP CPD tracking, insurer tie-up amendments, Code of Conduct under Schedule I IMF Regulations 2015, IRDAI inspection readiness.

Transparent Annual Fees: Rs 40,000 to Rs 1,00,000 per year across 3 tiers; calendar-year fixed-fee with monthly check-ins and automated deadline tracking across 25 to 35 filing events.

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Real Stories from Real People

Hear how teams across industries use Patron to save time, cut costs, & stay in control.

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We had been juggling a separate CA firm for audit and ITR, a CS firm for ROC, and an IMF compliance agent for IRDAI returns. Patron consolidated all three under one engagement at Rs 65,000 per year - half what we were paying across the three providers. Monthly check-ins keep us ahead of deadlines and we have not missed a single filing in 18 months.
AP
Ashok P.
Director, IMF in Maharashtra (Tier 2 Standard)
★★★★★
2 months ago
Our IMF underwent an IRDAI inspection in 2025 and we had everything ready because of Patron's compliance repository - half-yearly returns, ISP registers, Code of Conduct documentation, tie-up agreements, premium account reconciliations. Inspection closed with zero adverse remarks. The Tier 3 retainer paid for itself many times over.
MK
Manish K.
Principal Officer, IMF in Delhi (Tier 3 Comprehensive)
★★★★★
3 months ago
Single-district IMF in Pune with 4 ISPs and one life insurer. Patron's Tier 1 Lean at Rs 45,000 per year covers everything we need - IRDAI returns, ROC trio, ITR-6, audit coordination. Quarterly check-ins are enough at our scale. When we crossed Rs 20 lakh GST threshold, Patron flagged it immediately and added GST returns as a clean add-on.
DN
Deepa N.
Founder Director, IMF in Pune (Tier 1 Lean)
★★★★★
4 months ago
Patron's 3-year renewal coordination at the end of our first cycle was seamless - Net Worth Certificate refreshed in IRDAI format, all 10 ISP CPD records verified, Fit and Proper refreshed for the PO, document repository assembled for the renewal portal. Renewal approved without queries. The Tier 3 retainer including renewal coordination is worth every rupee.
SK
Sunita K.
CFO, Multi-State IMF (Tier 3 + Renewal)
★★★★★
5 months ago

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From Maharashtra Tier 2 consolidations to Delhi Tier 3 inspection-ready retainers - real Patron clients share how the compliance retainer simplified their year and protected their 3-year renewal record.

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Overview - IMF Compliance Retainer

📌 TL;DR - IMF Compliance Retainer Services at a Glance

Every Insurance Marketing Firm operates under five concurrent compliance regimes - IRDAI (half-yearly returns to IRDAI portal, Code of Conduct under Schedule I IMF Regulations 2015, Fit and Proper refresh, IRDAI inspection support), Companies Act 2013 (statutory audit, Board Meetings, AGM, ROC filings AOC-4 + MGT-7 + ADT-1 + DIR-3 KYC + DPT-3), Income Tax Act 1961 (ITR-6 for Pvt Ltd, tax audit under Section 44AB, TDS compliance), GST Act 2017 (monthly/quarterly GSTR-1 and GSTR-3B, annual GSTR-9 if registered), and Industry-Specific (ISMP / Principal Officer renewal, ISP onboarding, insurer tie-up amendments). Patron's retainer Rs 40,000 to Rs 1,00,000 per year across 3 tiers consolidates all five streams under one CA + CS engagement.

The IMF compliance landscape spans five regulators - IRDAI, MCA, Income Tax, GST, and industry counterparties (insurers). Compliance is continuous, not transactional. A typical IMF accumulates 25-35 filing events per year across these regulators - half-yearly IRDAI returns, monthly GST returns, annual ROC trio (AOC-4 + MGT-7 + ADT-1), annual DIR-3 KYC for each director, annual DPT-3, annual ITR-6, statutory audit, Board Meetings quarterly, Annual General Meeting, MBP-1 director disclosure, ISP renewal coordination, insurer tie-up amendments, and Code of Conduct self-certification. Missing or delayed filings attract late fees, penalties, ROC default tagging, IRDAI adverse remarks, and registration renewal scrutiny.

Patron's IMF compliance retainer consolidates all five regulatory streams under a single annual fixed-fee engagement (Rs 40,000 to Rs 1,00,000 across 3 tiers) with CA + CS coordination, monthly client check-ins, automated deadline tracking, document repository maintenance, and pre-emptive compliance health checks. Verify your portal status and IRDAI procedures at the Insurance Regulatory and Development Authority of India; ROC filings at the Ministry of Corporate Affairs (MCA21); income tax filings at the Income Tax India e-Filing Portal; and GST filings at the Goods and Services Tax Portal.

Content is reviewed quarterly for accuracy.

Five Regulatory Streams Every IMF Must Manage

IMF compliance is not a single regulator engagement - it spans five concurrent streams with 25 to 35 filing events per year. Each stream has its own forms, deadlines, and penalty schedule. The retainer consolidates all five under one CA + CS engagement.

Stream 1 - IRDAI: Half-yearly returns to the IRDAI portal with period ends 31 March (H2 covering October to March) and 30 September (H1 covering April to September); typically filed within 30 days of period end. Content includes business volumes, insurer-wise breakup, geography, ISP performance, customer servicing, Code of Conduct compliance under Schedule I IMF Regulations 2015, premium handling, net worth status, and Principal Officer continuity. Annual Code of Conduct self-certification by Principal Officer; Fit and Proper refresh; IRDAI inspection support when scheduled.

Stream 2 - Companies Act 2013: Statutory audit under Section 139 (mandatory for Pvt Ltd; LLP if turnover above Rs 40 lakh or capital above Rs 25 lakh); AGM within 6 months of FY end under Section 96; quarterly Board Meetings under Section 173; ROC trio - AOC-4 (financial statements) within 30 days of AGM under Section 137, MGT-7 (annual return) within 60 days of AGM under Section 92, ADT-1 (auditor appointment) within 15 days under Section 139; DIR-3 KYC by 30 September annually under Rule 12; DPT-3 deposit return annual under Rule 16; MBP-1 director disclosure at first Board Meeting of FY under Section 184.

Stream 3 - Income Tax Act 1961: ITR-6 for Pvt Ltd IMFs (ITR-5 for LLP) due 31 October (without TP audit) or 30 November (with TP audit) under Section 139; tax audit under Section 44AB if turnover exceeds Rs 1 crore (Rs 10 crore for digital transactions); Form 3CD tax audit report under Rule 6G; advance tax in 4 instalments (15 June, 15 September, 15 December, 15 March); TDS quarterly returns Form 26Q and 24Q; Form 16 / 16A issuance by 15 June; Section 234A interest at 1 percent per month on late filings.

Stream 4 - GST Act 2017: Registration mandatory if aggregate turnover crosses Rs 20 lakh (Rs 10 lakh in special category states) or for interstate supply; IMF commission income attracts GST at 18 percent. GSTR-1 outward supplies monthly (turnover above Rs 5 crore) or quarterly; GSTR-3B monthly tax payment; GSTR-9 annual return by 31 December; GSTR-9C reconciliation if turnover above Rs 5 crore; Reverse Charge Mechanism on certain expenses.

Stream 5 - Industry-Specific: ISMP / Principal Officer annual CPD hours tracking and renewal; ISP onboarding (25-hour sectoral training) and offboarding paperwork; insurer tie-up amendments (subject to 2 life + 2 general + 2 health cap under Regulation 3); customer complaint resolution under Schedule I; 3-year IMF Registration renewal cycle coordination.

Key Terms for IMF Compliance Retainer:

  • IRDAI Half-Yearly Return: Statutory IMF return filed twice a year through the IRDAI online portal - H1 within 30 days of 30 September period end; H2 within 30 days of 31 March period end. Covers business volumes, insurer-wise breakup, geography, ISP performance, customer servicing, Code of Conduct compliance, premium handling, net worth status, Principal Officer continuity.
  • Statutory Audit (Section 139 Companies Act 2013): Mandatory annual audit for Pvt Ltd IMFs regardless of turnover. LLP IMFs require statutory audit only if annual turnover exceeds Rs 40 lakh or capital contribution exceeds Rs 25 lakh. Audit report and audited financials must be ready before AGM.
  • AOC-4 / MGT-7 / ADT-1: ROC annual filing trio - AOC-4 (financial statements) within 30 days of AGM under Section 137; MGT-7 (annual return) within 60 days under Section 92; ADT-1 (auditor appointment) within 15 days of AGM or Board Meeting under Section 139.
  • DIR-3 KYC and DPT-3: DIR-3 KYC annual filing for each director with active DIN by 30 September under Rule 12 Companies Rules 2014; missing this deactivates the DIN. DPT-3 deposit return annual under Rule 16 Companies (Acceptance of Deposits) Rules 2014.
  • ITR-6 / Section 44AB Tax Audit: ITR-6 is the income tax return form for Pvt Ltd Companies (LLPs use ITR-5). Due 31 October (without TP audit) or 30 November (with TP audit). Tax audit under Section 44AB applies if turnover exceeds Rs 1 crore (Rs 10 crore for digital transactions); Form 3CD uploaded with ITR.
  • Schedule I IMF Regulations 2015 - Code of Conduct: Prescribed Code of Conduct for IMFs and ISPs covering customer protection, transparent disclosure, ethical solicitation, conflict-of-interest management, premium handling, and complaint resolution. Annual self-certification by Principal Officer to IRDAI.
  • ISMP and ISP CPD: Insurance Sales Management Programme (ISMP) for the Principal Officer and Continuing Professional Development for Insurance Sales Persons (ISP). Annual CPD hours tracking under Regulation 12; refresh at IMF Registration renewal.
  • 2L + 2G + 2H Cap (Regulation 3): An IMF can have a maximum of 2 life + 2 general + 2 health insurer tie-ups (6 total). Adding a 7th tie-up violates the regulation. Patron tracks tie-up additions and removals and prevents cap breach.
APL-05 IMF Compliance Retainer
Annual Engagement 5 Streams + 25-35 Filings + 3 Tiers

12-Month IMF Compliance Calendar (April-March FY)

The IMF compliance calendar runs on multiple cycles. Below is the consolidated 12-month view on a financial-year basis (April-March). Each month aligns to specific filings across IRDAI, Companies Act 2013, Income Tax, GST, and industry streams.

  • April: New FY commences. Board Meeting Q1 under Section 173. GSTR-1 March return (11 April for monthly filers); GSTR-3B March return (20 April). TDS payment for March (30 April). Prior FY books closing entries; statutory audit kickoff.
  • May: TDS return Q4 (Form 26Q, 24Q) due 31 May. GSTR-1 plus GSTR-3B for April. Form 16 / 16A preparation. Statutory audit fieldwork continues.
  • June: Statutory audit completion and signed audit report. Form 16 / 16A issuance to employees and vendors by 15 June. Advance tax Q1 instalment due 15 June (15 percent of estimated tax). GSTR-1 plus GSTR-3B for May.
  • July: Form FLA filing for ODI holdings by 15 July under FEMA OI Rules 2022. GSTR-1 plus GSTR-3B for June; Quarterly GSTR-1 if applicable. TDS Q1 return (Form 26Q, 24Q) due 31 July. Board Meeting Q2.
  • August: GSTR-1 plus GSTR-3B for July. AGM preparation - 21 days clear notice under Section 101.
  • September: AGM by 30 September under Section 96. ADT-1 within 15 days of AGM under Section 139. DIR-3 KYC for all directors by 30 September under Rule 12. Advance tax Q2 instalment due 15 September (45 percent cumulative). MBP-1 Director Disclosure under Section 184. IRDAI H1 period ends 30 September. Board Meeting Q3.
  • October: ITR-6 due 31 October for entities subject to statutory audit. IRDAI H1 Return Filing within 30 days of period end. AOC-4 within 30 days of AGM under Section 137. TDS Q2 return due 31 October. GSTR-1 plus GSTR-3B for September. MGT-14 if Special Resolution passed (within 30 days under Section 117(2)).
  • November: MGT-7 within 60 days of AGM under Section 92. ITR-6 due 30 November for entities with Transfer Pricing audit. Form DPT-3 deposit return annual under Rule 16. GSTR-1 plus GSTR-3B for October.
  • December: Advance tax Q3 instalment due 15 December (75 percent cumulative). GSTR-9 annual return for prior FY due 31 December. GSTR-9C reconciliation if turnover above Rs 5 crore. GSTR-1 plus GSTR-3B for November.
  • January: GSTR-1 plus GSTR-3B for December. TDS Q3 return due 31 January. Board Meeting Q4. Insurer tie-up renewal cycle if any insurers up for renewal.
  • February: GSTR-1 plus GSTR-3B for January. Pre-March financial year-end planning - tax planning, capital expenditure decisions.
  • March: Advance tax Q4 instalment due 15 March (100 percent cumulative). Financial year ends 31 March. IRDAI H2 period ends 31 March. GSTR-1 plus GSTR-3B for February. Year-end closing entries. ISMP and ISP CPD hours completion check for the FY.

Total filing events per year: 25 to 35 across the five regulatory streams. Each event has a hard statutory deadline; missing any creates penalty exposure and adverse remarks at IRDAI renewal scrutiny.

Patron Retainer Coverage Across 5 Regulatory Streams

ServiceWhat We Do
IRDAI Half-Yearly Returns (2 per year) H1 period end 30 September and H2 period end 31 March; filing within 30 days through IRDAI online portal. Coverage includes business volumes, insurer-wise breakup, geography, ISP performance, customer servicing, Code of Conduct, premium handling, net worth, PO continuity, material events. All Tiers
Code of Conduct Self-Certification (Schedule I) Annual PO self-certification to IRDAI under Schedule I IMF Regulations 2015 - customer protection, transparent disclosure, ethical solicitation, conflict-of-interest management, premium handling, complaint resolution. Tier 3 includes quarterly internal Code of Conduct reviews. All Tiers
Statutory Audit Coordination Audit firm engagement and coordination (Tier 1 coordination only; Tier 2 full coordination; Tier 3 full with detailed CARO 2020 responses and IFC assessment). Covers IMF-specific areas - commission revenue recognition, premium account reconciliation, net worth, ISP register, Code of Conduct documentation. All Tiers
ITR-6 Filing under Section 139 Income Tax Act 1961 ITR-6 for Pvt Ltd IMFs (ITR-5 for LLP) by 31 October (without TP audit) or 30 November (with TP audit). Tier 3 includes comprehensive tax planning. Tax audit under Section 44AB coordinated if turnover above Rs 1 crore. All Tiers
ROC Filings (AOC-4, MGT-7, ADT-1, DIR-3 KYC, DPT-3) AOC-4 within 30 days of AGM (Section 137); MGT-7 within 60 days (Section 92); ADT-1 within 15 days (Section 139); DIR-3 KYC by 30 September annually for each director (Rule 12); DPT-3 deposit return annual (Rule 16). MGT-14 for Special Resolutions handled as needed. All Tiers
GST Returns (Tier 2/3 included; Tier 1 add-on) GSTR-1 outward supplies monthly or quarterly; GSTR-3B monthly tax payment; GSTR-9 annual return by 31 December; GSTR-9C reconciliation if turnover above Rs 5 crore. RCM reporting where applicable. Tier 1 GST returns Rs 18,000 per year add-on. Tier 2 + 3
Board Meetings + AGM Coordination 4 Board Meetings per year under Section 173 (one per calendar quarter; gap not more than 120 days). AGM coordination with 21-day Notice under Section 101, AGM resolutions, minutes drafting. Tier 2 includes 1 AGM + 1 EGM; Tier 3 includes 1 AGM + up to 2 EGMs. Tier 2 + 3
ISMP / Principal Officer + ISP CPD Tracking Principal Officer annual CPD hours tracking and renewal; ISP CPD tracking up to 3 (Tier 1) / up to 5 (Tier 2) / up to 10 (Tier 3) with reminders. ISP onboarding and offboarding paperwork. Refresh at 3-year IMF Registration renewal. All Tiers
Insurer Tie-Up Amendment Paperwork Tie-up amendments subject to 2L + 2G + 2H cap under Regulation 3. Tier 1 - Rs 5,000 per amendment add-on; Tier 2 - up to 2 per year included; Tier 3 - up to 4 per year included. Tier 2 + 3
IRDAI Inspection Support Pre-inspection readiness check, on-site coordination, post-inspection response handling. Tier 1 - Rs 15,000 per inspection add-on; Tier 2 - up to 1 per cycle included; Tier 3 - up to 2 per cycle included. Tier 2 + 3
3-Year IMF Registration Renewal Coordination End-of-cycle renewal application coordination - Net Worth Certificate refresh, PO and ISP CPD verification, Fit and Proper refresh, document repository assembly, IRDAI portal renewal submission. Tier 1 / Tier 2 - add-on Rs 20,000 / Rs 15,000; Tier 3 - included. Tier 3 Included
Our Process

5-Phase IMF Compliance Retainer Onboarding

Patron's structured onboarding workflow takes a new compliance client from initial diagnostic through steady-state operation in 90 days, with backlog cleanup, system setup, and first quarter handled inside the retainer.

Step 1

Compliance Diagnostic and Status Review

Days 1-7 of onboarding. Patron reviews IRDAI returns history, ROC filings status, audit history, tax filings, GST registration, ISP register accuracy. Diagnostic memo identifies gaps and risk areas across all 5 regulatory streams - the basis for tier selection.

All 5 streams reviewed Gaps identified
Diagnostic 01
Step 2

Backlog Cleanup (If Any Overdue Filings)

Days 7-30. Address overdue filings - delayed AOC-4, MGT-7, DIR-3 KYC, missed half-yearly returns. Late fees paid, backlogs filed, status sheet produced. Clean slate before steady-state engagement begins.

Backlogs cleared Default tags removed
Cleanup Done 02
Step 3

Engagement Letter and Tier Selection

Days 7-14. Engagement letter signed; Tier 1 / Tier 2 / Tier 3 selected based on diagnostic; KYC of directors and Principal Officer; document repository initialised; access permissions configured for the client team.

Tier confirmed Repository created
T1 T2 T3
Tier Locked 03
Step 4

System Setup and Compliance Calendar

Days 14-30. Compliance calendar configured with all 25 to 35 filing events for the year; deadline alerts enabled (21 / 14 / 7 days before due); document templates created; client portal access provisioned. Compliance system fully operational.

25-35 events tracked Auto-reminders set
Calendar Live 04
Step 5

First Quarter Steady-State Operation

Days 30-90. First quarterly filings cycle handled across all 5 streams; client onboarding meetings; documentation flows established; first Board Meeting attended. Quarter completes with rhythm fully established and team familiarised.

Q1 filings complete Rhythm established
M1 M2 M3
Q1 Done 05
Step 6

IRDAI Half-Yearly Returns Cycle

Twice a year - H1 period end 30 September and H2 period end 31 March. Patron's workflow - data collection on Day 1 of period close, insurer reconciliation, ISP register snapshot, claims and complaint register review, draft compilation, PO sign-off 7 days before submission, portal filing within 30 days, acknowledgement archived.

Filed within 30 days PO sign-off
H1 H2
Returns Filed 06
Step 7

Year-End Audit, AGM, ROC Trio

April through November sequence - statutory audit completion by June end; AGM by 30 September under Section 96; ADT-1 within 15 days; AOC-4 within 30 days of AGM under Section 137; MGT-7 within 60 days under Section 92; DIR-3 KYC by 30 September; DPT-3 annual. ITR-6 by 31 October.

ROC trio filed ITR-6 by 31 Oct
Year-End Closed 07
Step 8

Annual Health Check and 3-Year Renewal

End-of-FY annual compliance health check across all 5 streams; action plan for next year. At 3-year IMF Registration renewal - Net Worth Certificate refresh, PO and ISP CPD verification, Fit and Proper refresh, document repository assembly, IRDAI portal renewal submission (included in Tier 3; Tier 1/2 add-on).

Health check delivered Renewal-ready record
Year Complete 08

Annual Compliance Document Inventory

For an effective retainer engagement, Patron maintains the following document inventory in the central compliance repository. The repository becomes the IRDAI inspection and 3-year renewal evidence pack.

  • IRDAI IMF Registration Certificate (with validity period)
  • Latest two half-yearly returns filed with IRDAI portal acknowledgements
  • Principal Officer Form A submission and Fit and Proper declarations
  • Principal Officer 50-hour IRDAI training certificate and current CPD record
  • ISP register - active list with KYC, certifications, F and P declarations, CPD hours
  • CA Net Worth Certificate in IRDAI format (refreshed annually within 60 days of 31 March)
  • Audited financial statements for prior 3 FYs and current audit report
  • ITR-6 filing acknowledgements for prior 3 FYs
  • Tax audit report (Form 3CD) under Section 44AB if applicable
  • ROC filing acknowledgements - AOC-4, MGT-7, ADT-1, DIR-3 KYC, DPT-3, MBP-1
  • Board Meeting minutes (4 per year minimum) and AGM minutes
  • Insurer tie-up agreements (life / general / health) with renewal status
  • GST registration certificate, GSTR-1, GSTR-3B, GSTR-9 filing acknowledgements
  • TDS Quarterly returns (Form 26Q, 24Q) and Form 16 / 16A issuance records
  • Premium collection bank account statements and reconciliation
  • Customer complaint register with resolution TAT data
  • Code of Conduct compliance manual and annual PO self-certification
  • Internal incident register (any Schedule I breaches with remediation tracking)
  • Office rental agreement, address proofs, MoA, AoA, certificate of incorporation

Verify portal status and IRDAI procedures at the IRDAI main site and the IRDAI Insurance Marketing Firm portal; ROC at the Ministry of Corporate Affairs (MCA21); income tax at the Income Tax e-Filing Portal; GST at the GST Portal; and auditing standards at the Institute of Chartered Accountants of India.

Common IMF Compliance Mistakes and How We Prevent Them

ChallengeImpactHow Patron Accounting Solves It
Half-Yearly IRDAI Return Filed Late Returns must be filed within 30 days of period end (31 March or 30 September). Late filing attracts IRDAI adverse remarks and impacts 3-year renewal scrutiny - registration cancellation possible in cumulative non-compliance scenarios. Patron's deadline tracker triggers preparation 21 days before due date with Principal Officer sign-off 7 days before portal submission. Insurer reconciliation and ISP register snapshot taken on Day 1 of period close.
ADT-1 Not Filed Within 15 Days of AGM Section 139 Companies Act 2013 requires auditor appointment notification via Form ADT-1 within 15 days of AGM or Board Meeting. Many IMFs file this late or miss it entirely - leading to default tagging on MCA21 and late fees up to 12x normal under Section 403. Patron's AGM workflow includes ADT-1 filing on the same day as AGM or the next working day. ADT-1 readiness is verified during the AGM Notice preparation phase three weeks before AGM.
DIR-3 KYC Missed Annually for Directors Every director with active DIN must file DIR-3 KYC by 30 September each year under Rule 12. Missing DIR-3 KYC results in DIN deactivation - blocking all future e-form filings - plus Rs 5,000 per director reactivation fee. Patron tracks DIR-3 KYC status for all client directors monthly. Reminder alerts issued at 60 / 30 / 7 days before 30 September; filing completed in August or first week of September.
GST Registration Delayed Past Rs 20 Lakh Threshold Aggregate turnover above Rs 20 lakh (Rs 10 lakh in special category states) requires GST registration within 30 days under GST Act 2017. Delay invites Section 122 CGST penalty plus retrospective GST liability on turnover from threshold crossover date. Patron monitors turnover quarterly and flags threshold approach at 75 percent of limit (Rs 15 lakh / Rs 7.5 lakh). Registration application initiated immediately on crossing to avoid retrospective liability.
Insurer Tie-Up Beyond 2L + 2G + 2H Cap IRDAI IMF Regulations 2015 cap insurer tie-ups at 2 life + 2 general + 2 health (6 total). Operations entering a 7th tie-up violate the regulation under Regulation 3 - potential adverse remarks at IRDAI inspection. Patron tracks tie-up additions and removals in real time within the document repository. New tie-up additions are validated against current cap status before any insurer outreach is initiated.
ISMP / Principal Officer CPD Lapse Principal Officer requires annual CPD hours. Lapse is not typically flagged until the IRDAI 3-year renewal cycle - by which point PO recertification may be required, delaying the renewal and creating IRDAI clarification queries. Patron tracks CPD hours monthly for the PO and ISP team. Course enrolment is arranged proactively well before the FY end so CPD completion is documented during the steady state, not in renewal scramble.

Patron 3-Tier Compliance Retainer Fees (Annual)

Fee ComponentAmount
Free IMF Compliance Retainer Scoping Call Free - 30-minute scoping call plus 5-stream compliance status assessment plus tier recommendation memo; response within 4 hours
Patron Accounting Professional Fees (entry-level retainer add-on) Starting from INR 2,999 (Exl GST and Govt. Charges) for the initial diagnostic-only sub-engagement; credit applied if Tier 1 / 2 / 3 retainer engaged within 30 days
Tier 1 - Lean Compliance Retainer (per year) Rs 40,000 to Rs 50,000 per year - small IMFs, single-district operation, 2-5 ISPs, single insurer tie-up, modest commission turnover, minimal complexity
Tier 2 - Standard Compliance Retainer (per year) Rs 55,000 to Rs 75,000 per year - medium IMFs, 1-3 districts, 5-10 ISPs, 2-4 insurer tie-ups, commission turnover Rs 50 lakh to Rs 2 crore; includes TDS, GST, Board Meetings, AGM
Tier 3 - Comprehensive Compliance Retainer (per year) Rs 75,000 to Rs 1,00,000 per year - large IMFs, multi-state, 10+ ISPs, multiple tie-ups (life + general + health), commission turnover above Rs 2 crore; includes 3-year renewal coordination
Tier 1 Add-On - TDS Quarterly Returns Rs 8,000 per year - quarterly Form 26Q and 24Q TDS returns under Section 200; Form 16 / 16A issuance by 15 June
Tier 1 Add-On - GST Monthly / Quarterly + Annual Returns Rs 18,000 per year - GSTR-1 outward supplies, GSTR-3B tax payment, GSTR-9 annual return; included in Tier 2 and Tier 3
Tier 1 Add-On - AGM Coordination plus EGM Rs 8,000 per year - AGM Notice under Section 101 (21-day clear notice), AGM resolutions, minutes drafting; EGM if special resolutions required
Tier 1 Add-On - Insurer Tie-Up Amendment Rs 5,000 per amendment - tie-up amendment paperwork; cap monitoring under Regulation 3 (2L + 2G + 2H). Tier 2 - up to 2 per year included; Tier 3 - up to 4 per year
Tier 1 Add-On - IRDAI Inspection Support Rs 15,000 per inspection - pre-inspection readiness check, on-site coordination, post-inspection response handling. Tier 2 - 1 per cycle included; Tier 3 - up to 2 per cycle
3-Year IMF Registration Renewal Coordination Tier 1 add-on Rs 20,000; Tier 2 add-on Rs 15,000; Tier 3 included. End-of-cycle renewal application coordination - Net Worth Certificate refresh, PO and ISP CPD verification, Fit and Proper refresh, document repository assembly, IRDAI portal renewal submission

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

Get a free IMF Compliance Retainer consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

Late Filing Penalty Schedule

StageEstimated Timeline
AOC-4 (Financial Statements) Within 30 days of AGM under Section 137 - late fee Rs 100 per day continuing default until filing; financial statements deemed not filed
MGT-7 (Annual Return) Within 60 days of AGM under Section 92 - late fee Rs 100 per day continuing default; Annual Return deemed not filed
ADT-1 (Auditor Appointment) Within 15 days of AGM or Board Meeting under Section 139 - late filing fee up to 12x normal under Section 403
DIR-3 KYC (Director KYC) By 30 September annually under Rule 12 - Rs 5,000 late fee per director plus DIN deactivation (blocks all future e-form filings)
DPT-3 (Deposit Return) By 30 June annually under Rule 16 - Rs 100 per day continuing default
MGT-14 (Special Resolutions) Within 30 days of resolution under Section 117(2) - Rs 10,000 plus Rs 100 per day continuing default
ITR-6 (Income Tax Return) 31 October (without TP audit) or 30 November (with TP audit) - Section 234A interest at 1 percent per month plus Section 234F late fee up to Rs 10,000
GSTR-1 / GSTR-3B (Monthly or Quarterly) Per filing schedule - late fee Rs 50 per day (Rs 20 per day for nil return) plus interest 18 percent per annum on tax
GSTR-9 (Annual GST Return) By 31 December - late fee Rs 200 per day capped at 0.25 percent of turnover
IRDAI Half-Yearly Return Within 30 days of period end (31 March or 30 September) - authority adverse remarks; impacts 3-year renewal scrutiny; possible compounding action

Cumulative Risk: Individual late fees are small but cumulative non-compliance over a 3-year cycle materially impacts IMF Registration renewal scrutiny. IRDAI's renewal evaluation considers the entire compliance history - missed half-yearly returns, ROC default tagging, ITR delays, GST defaults, and any documented Code of Conduct breaches collectively determine renewal outcome. Patron's retainer is calibrated to keep the entire compliance record clean across the 3-year cycle - the 25 to 35 filing events are tracked with 21 / 14 / 7 day reminders, and a monthly check-in cadence (Tier 2 / Tier 3) ensures nothing slips through.

Key Benefits

Why Patron for IMF Compliance Retainer

Single Firm CA + CS Coordination

All five regulatory streams - IRDAI, MCA, Income Tax, GST, industry-specific - under one CA + CS engagement. Eliminates inter-firm coordination friction; reduces fee total by 30-50 percent vs the traditional fragmented model.

Automated Deadline Tracking

25-35 filing events per year tracked with auto-reminders 21 / 14 / 7 days before due date. Monthly client check-in calls (Tier 2; bi-monthly Tier 3) keep compliance proactive rather than reactive. Quarterly reviews and annual health check.

IRDAI Inspection Readiness

Document repository maintained across all filings, certificates, returns and registers. At IRDAI inspection or 3-year renewal, the entire evidence pack is one click away - half-yearly returns, ISP registers, tie-up agreements, premium account reconciliations, Code of Conduct documentation.

Transparent 3-Tier Fixed Fees

Rs 40,000 to Rs 1,00,000 per year with clear inclusion matrix across 20 compliance areas. No hourly billing surprises. Tier selection based on diagnostic; tier upgrades available at year boundaries.

Specialised IMF Compliance Focus

Dedicated IMF cluster understanding vs generic CA firm coverage. Recurring revenue engagement bridging from one-time setup engagements (incorporation, IRDAI registration, ISMP / ISP coordination) to long-term operational compliance partnership.

15+ Years Cross-Regulator Practice

Offices in Pune, Mumbai, Delhi and Gurugram with pan-India remote engagement. 15+ years experience across IRDAI, MCA, CBDT, GST and other regulators. Sister-service synergy - PO / ISP coordination, valuation, GST, accounting available within the same firm.

Trusted by IMFs for Annual Compliance Continuity

Trust Banner: 10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years in Practice

"We had been juggling a separate CA firm for audit and ITR, a CS firm for ROC, and an IMF compliance agent for IRDAI returns. Patron consolidated all three under one engagement at Rs 65,000 per year - half what we were paying across the three providers. Monthly check-ins keep us ahead of deadlines and we have not missed a single filing in 18 months."

- Director, IMF in Maharashtra

"Our IMF underwent an IRDAI inspection in 2025 and we had everything ready because of Patron's compliance repository - half-yearly returns, ISP registers, Code of Conduct documentation, tie-up agreements, premium account reconciliations. Inspection closed with zero adverse remarks. The Tier 3 retainer paid for itself many times over."

- Principal Officer, IMF in Delhi

Client Logos: Trusted by Hyundai, Asian Paints, Bridgestone and a roster of IMFs across India - small single-district outfits, medium multi-district operations, and large multi-state firms serving life, general and health insurance distribution.

4-Office Trust Signal: With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves IMF clients across India with consistent senior CA + CS coordination and pan-India remote engagement for client teams operating outside the four office cities.

3-Tier Coverage Matrix - Tier 1 / Tier 2 / Tier 3

Compliance AreaTier 1 - Lean (Rs 40-50K/yr)Tier 2 - Standard (Rs 55-75K/yr)Tier 3 - Comprehensive (Rs 75K-1L/yr)
IRDAI Half-Yearly Returns (2x per year) Included Included Included
Code of Conduct Self-Certification Annual Annual Annual + quarterly internal review
Statutory Audit Coordination Coordination only Full coordination Full with CARO 2020 + IFC responses
ITR-6 Filing Included Included Included with tax planning
TDS Quarterly Returns Add-on Rs 8,000/yr Included Included
GST Monthly/Quarterly + GSTR-9 Add-on Rs 18,000/yr Included Included
ROC Filings (AOC-4, MGT-7, ADT-1) Included Included Included
DIR-3 KYC + DPT-3 Included Included Included
Board Meetings (4 per year) + MBP-1 Add-on Rs 6,000/yr Included Included
AGM Coordination + EGM Add-on Rs 8,000/yr 1 AGM + 1 EGM included 1 AGM + up to 2 EGMs included
ISMP / Principal Officer CPD Limited tracking Included Included with reminders
ISP CPD Tracking Up to 3 ISPs Up to 5 ISPs Up to 10 ISPs
Insurer Tie-Up Amendment Paperwork Add-on Rs 5,000 each Up to 2 per year Up to 4 per year
IRDAI Inspection Support Add-on Rs 15,000 per inspection 1 per cycle included Up to 2 per cycle included
Customer Complaint Resolution Support Not Included Up to 5 cases Up to 15 cases
Client Check-In Cadence Quarterly Monthly Bi-monthly
Annual Compliance Health Check Included Included Included with action plan
Document Repository Limited Included Included with cloud client access
3-Year Renewal Application Coordination Add-on Rs 20,000 Add-on Rs 15,000 Included
Best Fit For Small IMFs, single-district, 2-5 ISPs, 1 insurer Medium IMFs, 1-3 districts, 5-10 ISPs, 2-4 insurers Large IMFs, multi-state, 10+ ISPs, multiple tie-ups

Related Patron Services Within and Beyond the IMF Cluster

The compliance retainer is the recurring revenue engine of Patron's IMF cluster - bridging from one-time setup engagements to long-term operational compliance partnership. Related services help across the engagement lifecycle:

Verify your portal status and IRDAI procedures at the IRDAI main site and the IRDAI Insurance Marketing Firm portal. ROC filings on the Ministry of Corporate Affairs (MCA21) portal. Income tax at the Income Tax India e-Filing Portal. GST at the GST Portal. Auditing standards at the Institute of Chartered Accountants of India.

Legal and Compliance Framework (India)

Governing Statutes and Regulations: IRDAI Act 1999, Insurance Act 1938 (Sections 42D, 42E), IRDAI (Registration of Insurance Marketing Firm) Regulations 2015, Companies Act 2013, Companies Rules 2014, Income Tax Act 1961, GST Act 2017, and CGST Rules 2017.

  • IRDAI Act 1999 and Insurance Act 1938 Sections 42D, 42E: Statutory framework for insurance intermediaries including IMF category.
  • IRDAI (Registration of Insurance Marketing Firm) Regulations 2015: Master regulation - notified 21 January 2015.
  • Regulation 11 IMF Regulations 2015: Obligations and Code of Conduct compliance.
  • Schedule I IMF Regulations 2015: Code of Conduct for IMFs and ISPs.
  • Schedule II IMF Regulations 2015: Fit and Proper criteria - annual refresh required.
  • IRDAI Master Circular on Insurance Intermediaries: Half-yearly returns format and timeline.
  • IRDAI (Manner of Receipt of Premium) Regulations 2002: Premium collection compliance.
  • Section 92 Companies Act 2013: Annual Return (Form MGT-7) within 60 days of AGM.
  • Section 96 Companies Act 2013: AGM within 6 months of FY end; max 15 months between two AGMs.
  • Section 134 Companies Act 2013: Board's Report disclosures.
  • Section 137 Companies Act 2013: Financial Statements filing (Form AOC-4) within 30 days of AGM.
  • Section 139 Companies Act 2013: Auditor appointment (Form ADT-1) within 15 days.
  • Section 173 Companies Act 2013: Board Meetings minimum 4 per year for Pvt Ltd; one per calendar quarter; gap not more than 120 days.
  • Section 184 Companies Act 2013: Director Disclosure of Interest (Form MBP-1) annually.
  • Section 188 Companies Act 2013: Related Party Transactions approval.
  • Rule 12 Companies (Appointment and Qualification of Directors) Rules 2014: DIR-3 KYC by 30 September annually.
  • Rule 16 Companies (Acceptance of Deposits) Rules 2014: Form DPT-3 annual.
  • Section 44AB Income Tax Act 1961: Tax audit if turnover exceeds Rs 1 crore (Rs 10 crore for digital).
  • Section 139 Income Tax Act 1961: ITR filing due dates (31 October ITR-6 without TP audit; 30 November with TP audit).
  • Section 234A and 234F Income Tax Act 1961: Late filing interest at 1 percent per month plus late fee up to Rs 10,000.
  • GST Act 2017: Registration threshold Rs 20 lakh aggregate turnover (Rs 10 lakh special category states).
  • Section 39, 44, 47 CGST Act 2017: GSTR-1, GSTR-3B, and GSTR-9 filing framework.
  • Section 51, 52 CGST Act 2017: TDS and TCS provisions where applicable.
  • Companies (Auditor Report) Order 2020 (CARO 2020): Reporting clauses for statutory audit applicable to Pvt Ltd meeting thresholds.

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work, ISP team size, insurer tie-up count, and the number of inspection or special filing events during the year.

What are the annual compliance requirements for an IMF?

IMF compliance spans five regulatory streams - IRDAI (half-yearly returns to IRDAI portal with period ends 31 March and 30 September, Code of Conduct compliance under Schedule I, Fit and Proper refresh, IRDAI inspection support), Companies Act 2013 (statutory audit, AGM, ROC filings AOC-4 plus MGT-7 plus ADT-1 plus DIR-3 KYC plus DPT-3, MBP-1, Board Meetings), Income Tax (ITR-6 for Pvt Ltd, tax audit under Section 44AB if applicable, TDS quarterly returns), GST (registration if turnover above Rs 20 lakh, GSTR-1, GSTR-3B, GSTR-9), and Industry-Specific (ISMP / PO renewal, ISP onboarding, insurer tie-up amendments). Total 25-35 filing events per year.

When are IMF half-yearly returns due to IRDAI?

IRDAI half-yearly return period ends are 31 March (H2 covering October to March) and 30 September (H1 covering April to September). Returns are typically filed within 30 days of period end through the IRDAI online portal. Content includes business volumes, insurer-wise breakup, geography, ISP performance, customer servicing, Code of Conduct compliance, premium handling, net worth status, Principal Officer continuity, and material events. Late filing attracts IRDAI adverse remarks impacting 3-year renewal scrutiny.

Is statutory audit mandatory for an Insurance Marketing Firm?

Yes for Pvt Ltd IMF entities under Section 139 Companies Act 2013 - statutory audit mandatory regardless of turnover. LLP IMFs require statutory audit if annual turnover exceeds Rs 40 lakh or capital contribution exceeds Rs 25 lakh. Audit covers IMF-specific areas including insurer commission revenue recognition, premium collection bank account reconciliation, customer money handling under Manner of Receipt of Premium Regulations 2002, net worth confirmation, ISP register accuracy, Code of Conduct documentation, insurer tie-up compliance, and CARO 2020 disclosures where applicable.

What ROC filings does an IMF need to do?

Annual ROC filings - (1) AOC-4 (Financial Statements) within 30 days of AGM under Section 137; (2) MGT-7 (Annual Return) within 60 days of AGM under Section 92; (3) ADT-1 (Auditor Appointment) within 15 days of AGM or Board Meeting under Section 139; (4) DIR-3 KYC for each director by 30 September under Rule 12; (5) DPT-3 (Deposit Return) annual under Rule 16. Additional filings as needed - MGT-14 for Special Resolutions, INC-22 for office change, DIR-12 for director changes. LLPs file Form 8 and Form 11 instead of AOC-4 and MGT-7.

What is the cost of IMF compliance per year?

Patron's 3-tier fixed-fee retainer - Tier 1 Lean (Rs 40,000 to Rs 50,000 per year) for small IMFs with minimal complexity; Tier 2 Standard (Rs 55,000 to Rs 75,000 per year) for medium IMFs including TDS, GST, Board Meetings, AGM, ISP CPD up to 5; Tier 3 Comprehensive (Rs 75,000 to Rs 1,00,000 per year) for large IMFs with multi-state operations, 10+ ISPs, multiple tie-ups, inspection history, includes 3-year renewal coordination. All tiers include IRDAI half-yearly returns, ROC filings, ITR-6, statutory audit coordination, and annual compliance health check.

Does an IMF need GST registration?

Yes if aggregate turnover (commission income from insurers) crosses the Rs 20 lakh threshold (Rs 10 lakh in special category states) or if any interstate supply. Most operational IMFs eventually cross the threshold. IMF commission income from insurers attracts GST at 18 percent. Monthly or quarterly GSTR-1 and GSTR-3B filing required; annual GSTR-9 by 31 December; GSTR-9C reconciliation statement if turnover above Rs 5 crore. Reverse Charge Mechanism applies on certain inward supplies.

How does IRDAI inspect IMFs?

IRDAI may inspect IMFs periodically (typically during the 3-year renewal cycle) or for-cause (customer complaints, regulatory red flags, market intelligence). Inspection covers - documentation review (half-yearly returns, ISP registers, tie-up agreements, premium account reconciliations, Code of Conduct documentation), office and infrastructure verification, interviews with Principal Officer and select ISPs, customer file sampling, and regulatory adherence assessment. Patron's compliance retainer includes IRDAI inspection support - pre-inspection readiness check, on-site coordination, and post-inspection response handling.

What happens if an IMF misses compliance deadlines?

Consequences vary by filing - ROC penalties Rs 100 per day continuing default for AOC-4 and MGT-7; Section 117(2) penalty Rs 10,000 plus Rs 100 per day for MGT-14; DIR-3 KYC default Rs 5,000 per director and DIN deactivation; Income Tax late filing interest Section 234A at 1 percent per month plus late fee Section 234F up to Rs 10,000; GST late fees Rs 50 per day plus interest 18 percent per annum; IRDAI adverse remarks impacting 3-year renewal. Cumulative non-compliance can result in IMF registration suspension or cancellation.

Quick Answers

  • How many Board Meetings per year? Minimum 4 for Pvt Ltd under Section 173; one in each calendar quarter; gap not more than 120 days.
  • Is MBP-1 filed every year? Director Disclosure of Interest is given at the first Board Meeting of each FY under Section 184; required when any change occurs; maintained in records (not a ROC filing).
  • Can audit and IMF compliance be handled by the same firm? Yes, preferred. Single-firm coordination eliminates fragmentation. Patron handles both within the retainer.
  • Does GSTR-9C apply to all IMFs? Only if turnover above Rs 5 crore in the FY. Most small and medium IMFs file only GSTR-9 annual return.
  • When is AGM due? By 30 September following FY end under Section 96; first AGM within 9 months of incorporation.
  • Is CARO 2020 applicable to all Pvt Ltd IMFs? CARO 2020 applies if paid-up capital and reserves above Rs 1 crore OR borrowings above Rs 1 crore OR turnover above Rs 10 crore. Many small IMFs are below thresholds.
  • Can the compliance retainer be billed monthly? Yes. Patron offers monthly billing on the annual retainer at one-twelfth of the annual fee per month plus GST.
  • How is ISP renewal coordinated annually? ISPs require annual CPD hours - typically 15 hours per sectoral certification. Patron tracks CPD completion for each ISP, arranges course enrolment through IRDAI-approved institutes, refreshes Fit and Proper, and updates the IMF internal ISP register.
  • IMF ka annual compliance kya hota hai? Paanch regulators ke under - IRDAI half-yearly returns, Companies Act ROC trio, Income Tax ITR-6, GST returns, ISMP/PO/ISP renewal. Total 25-35 filing events. Patron Rs 40,000 se Rs 1,00,000 per year 3 tiers mein cover karta hai. Call +91 945 945 6700.

Act Before the Next Half-Yearly Return Window

Critical Window: IRDAI half-yearly returns have a 30-day filing window after each period end (31 March and 30 September). Missing the window creates IRDAI adverse remarks that follow the IMF into the 3-year renewal evaluation. Engage Patron at least 60 days before the next period close so data collection, reconciliation, and Principal Officer sign-off happen well within the statutory window.

Cost of Cumulative Non-Compliance: Individual late fees seem small - Rs 100 per day for AOC-4 / MGT-7; Rs 5,000 per director for DIR-3 KYC plus DIN deactivation; Section 234F up to Rs 10,000 for late ITR-6; GST Rs 50 per day plus 18 percent per annum interest. Cumulatively over a 3-year cycle, the financial penalty plus reputational impact at renewal can dwarf the entire compliance retainer fee.

Best Time to Engage: Onboarding cycle is 90 days end-to-end (diagnostic, backlog cleanup, engagement letter, system setup, first quarter steady state). Engaging Patron in early Q1 (April or July) gives the cleanest start; engaging just before period close means backlog risk transfers to the new retainer.

Action: Call +91 945 945 6700 for a free 30-minute IMF Compliance Retainer Scoping Call. Tier 1 from Rs 40,000; Tier 2 from Rs 55,000; Tier 3 from Rs 75,000.

Talk to Patron's IMF Compliance Retainer Team Today

IMF compliance is a 5-regulator, year-round engagement with 25 to 35 filing events including IRDAI half-yearly returns (period ends 31 March and 30 September), statutory audit under Section 139 Companies Act 2013, ROC filings (AOC-4, MGT-7, ADT-1, DIR-3 KYC, DPT-3), ITR-6 income tax filing, GST returns where applicable, Board Meetings and AGM, ISMP / Principal Officer and ISP renewal coordination, insurer tie-up amendments, Code of Conduct compliance under Schedule I IMF Regulations 2015, and IRDAI inspection support.

Patron's 3-tier annual fixed-fee retainer Rs 40,000 to Rs 1,00,000 per year consolidates all five regulatory streams under a single CA + CS coordinated engagement with monthly check-ins (Tier 2; bi-monthly Tier 3), automated deadline tracking, document repository maintenance, annual compliance health check, and 3-year IMF Registration renewal coordination (included in Tier 3; add-on for Tier 1 / Tier 2). Consolidation reduces fee total by 30 to 50 percent versus the traditional fragmented model of separate CA firm (audit, tax), CS firm (ROC), IMF compliance agent (IRDAI returns), and GST consultant.

The retainer is the recurring revenue engine of the Patron IMF cluster - bridging from one-time setup engagements (incorporation, IRDAI registration, ISMP / ISP coordination) to long-term operational compliance partnership. The firm serves IMFs across Pune, Mumbai, Delhi, and Gurugram with pan-India remote engagement for client teams operating outside the four office cities.

Book a Free Consultation - No Obligation.

Patron IMF Cluster Services

The compliance retainer sits at the centre of Patron's comprehensive IMF cluster. Sister pages cover entity setup, IRDAI registration, persona-specific routes, and rejection recovery.

Patron Offices Serving IMF Compliance Clients
4-office network with pan-India remote engagement for IMF retainer clients across India

Content Created: 11 May 2026  |  Last Updated: 11 May 2026  |  Next Review: 11 August 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed quarterly (Tier 2 - 3 months) and immediately on IRDAI return format updates, Companies Act 2013 ROC compliance amendments, ITR-6 form changes, GST law revisions, ISMP / ISP CPD requirement changes, and any IRDAI Master Circular updates affecting IMF intermediary compliance.

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