The Problem
A policyholder receives a call, SMS, or email claiming their life, health, or motor policy has lapsed and must be “revived” or “renewed” immediately, failing which the accumulated bonus, sum assured, or no-claim benefit will be forfeited. The message often carries an insurer’s logo, a plausible policy number, and a UPI QR code or bank account for “renewal premium.” The consumer, anxious not to lose cover or past benefits, pays without verifying the source. In many cases the policy was never actually due for renewal, the caller has no connection to the insurer, or the amount demanded bears no relation to the actual premium schedule on file. This is the fake renewal notice and lapsed-policy revival scam: a form of impersonation fraud that exploits the ordinary anxiety around lapsed cover and the general public’s limited familiarity with how insurers actually communicate renewal demands.
Distinguishing the Parties Involved
A renewal or revival communication may originate from several distinct sources, and the consumer’s remedy depends on correctly identifying which one is actually involved. The insurer itself communicates renewal due dates and grace periods, typically through its registered channels or the customer portal/app. An insurance agent or corporate agent (such as a bank selling insurance under bancassurance arrangements) may legitimately follow up on a renewal on the insurer’s behalf. A web aggregator or online platform through which the policy was originally purchased may also send renewal reminders. A surveyor or third-party administrator (TPA) is ordinarily concerned with claims investigation and health-claim processing, not premium collection — a consumer should not treat a renewal demand as genuine merely because the caller identifies themselves as a surveyor or TPA, and should independently verify any such claim. Fraudsters frequently impersonate one or more of these roles — for instance, describing themselves as an “IRDAI-authorised renewal agent.” A person should not be treated as an authorised insurance representative merely because they claim to be “IRDAI-authorised”; IRDAI is the regulator, and the intermediary’s identity and authorisation should be independently verified through the insurer or the appropriate regulatory records, not taken on the caller’s word.
What Evidence Establishes Authenticity
The policy document and the insurer’s official records should be used to verify the policy number, coverage, and renewal terms; because premium can change with applicable rates, product terms, age, or tax revisions, the current amount actually due should still be independently confirmed through the insurer’s official channel rather than assumed from the original document alone. The source of communication is a useful but not conclusive signal — genuine reminders are more likely to come through an insurer’s own registered channels, an authorised intermediary, or an approved communication service, but the appearance of a message, however official-looking, should never be relied on by itself. The safest practice is to independently verify any renewal demand through the insurer’s official portal or app, or by calling the customer care number printed on the original policy document — never a number or link provided in the demand itself. On the payment channel: consumers should pay only through channels officially authorised and identified by the insurer; a request to transfer money to a personal bank account or personal UPI ID is a major warning sign and should be independently verified with the insurer before any payment is made. Documentary consistency also matters — a genuine renewal premium receipt should carry the insurer’s IRDAI registration number, GST details, and a verifiable receipt number checkable on the insurer’s portal; inconsistent formatting, mismatched policy numbers, or an apparently doctored PDF are warning signs.
Civil Deficiency, Unfair Trade Practice, or Criminal Fraud?
Not every renewal-related complaint is a scam, and the applicable legal characterisation depends on the facts. Where a genuine insurer or its authorised agent sends a renewal reminder that is merely inaccurate (wrong due date, wrong premium figure due to a processing error), this is ordinarily a service deficiency remediable through the insurer’s own grievance mechanism and, if unresolved, the Consumer Protection Act, 2019. Where an authorised intermediary misrepresents the terms of renewal or bundles unauthorised riders to extract additional payment, this may amount to an unfair trade practice or a regulatory breach of the IRDAI (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024 and the IRDAI master circular on policyholder protection dated 5 September 2024 — whether it actually qualifies as an unfair trade practice under the Consumer Protection Act depends on the statutory definition and the specific facts, and this should not be assumed automatically from every regulatory lapse. Where the communication instead originates from a person with no genuine connection to the insurer, using a fabricated policy number, cloned branding, and a personal payment channel, with the specific intent to deceive the consumer into parting with money, this may amount to criminal fraud. Depending on the conduct involved, this may attract cheating or cheating-by-personation offences under the Bharatiya Nyaya Sanhita, 2023 (Sections 318 and 319, subject to the specific facts satisfying their ingredients), and, where the statutory ingredients are independently satisfied, relevant provisions of the Information Technology Act, 2000 — the use of electronic communication, a phishing link, or a cloned website does not by itself automatically attract the IT Act; applicability depends on the facts. The distinction matters because it determines whether the consumer’s remedy lies against the insurer (deficiency/regulatory route) or requires a police complaint and cybercrime reporting (criminal route) — and guilt should never be assumed of an intermediary merely because a scam has occurred; the specific role of each actor named in the complaint must be established on the facts before any characterisation is made.
The Remedy Path
Where the consumer has already paid a fraudulent “renewal” demand, the transaction should be reported immediately to the bank, payment service provider, or UPI provider, and the incident reported through the National Cybercrime Reporting Portal (cybercrime.gov.in) or the 1930 helpline. Prompt reporting may assist authorities and financial institutions in attempting to trace or freeze the transferred funds, but recovery of the money is not guaranteed. Where the fraud impersonated a genuine insurer, the insurer’s own fraud/grievance cell should also be notified.
Where the grievance instead concerns a genuine but mishandled renewal by the insurer or its authorised agent, the consumer should ordinarily first approach the insurer’s own Grievance Redressal Officer. If the complaint is not resolved within the applicable timeline, or the response is unsatisfactory, the policyholder may use the Bima Bharosa/IRDAI grievance mechanism, and may also approach the Insurance Ombudsman where the complaint falls within the Ombudsman’s jurisdiction and the applicable procedural requirements are satisfied. These routes should not be treated as a rigid, mandatory single sequence that must be exhausted step by step in every case — the appropriate route depends on the nature of the complaint, the insurer’s response, and the Ombudsman’s specific jurisdiction. Independently of these regulatory routes, a civil complaint before the appropriate Consumer Commission remains available for deficiency in service.
Important: Bima Bharosa does not ask policyholders or complainants to make any payment, and does not ask users to scan a QR code to receive a disbursement. Consumers should access the official Bima Bharosa portal directly rather than relying on a link or QR code received from an unknown person.
Red Flags at a Glance
Red Flag
What To Do
Demand to pay into a personal bank account or personal UPI ID
Do not pay; verify directly with the insurer through its official channel
Urgent threat that the policy or bonus will be lost within hours
Check the policy status yourself on the insurer’s official portal or app
Unknown caller claiming to be “IRDAI-authorised”
Independently verify identity and authorisation with the insurer; do not rely on the caller’s claim
QR code sent by an unknown caller or on WhatsApp/SMS
Do not scan it
Payment link embedded in an unsolicited SMS or email
Do not click; open the insurer’s website or app manually instead
Renewal amount differs from the insurer’s own records
Contact the insurer before paying anything
Prevention and Reform
At the level of individual precaution, consumers can protect themselves by never acting on a renewal link or payment request received unsolicited, independently verifying due premium through the insurer’s official app or portal, and treating any request to pay into a personal account or personal UPI ID as a warning sign regardless of how official the message appears. At a systemic level, insurers bear a significant share of the responsibility for consumer education — clearly publishing their officially authorised communication channels and payment modes, and running periodic public alerts about impersonation trends, consistent with the IRDAI’s policyholder protection framework. Where impersonation scams involve misuse of insurer branding, payment channels, or electronic communications, regulators, insurers, and the relevant law-enforcement authorities may need to coordinate on a case-by-case basis; this article does not assume any particular enforcement mechanism beyond the grievance and reporting channels described above. At the same time, safeguards are needed against false or retaliatory complaints — for instance, a consumer who simply missed a due date and later disputes a genuine renewal collection as “fraudulent” to avoid the consequences of lapse should not be permitted to misuse the impersonation framework to escape a legitimate premium obligation; insurers and Ombudsman offices should verify the actual communication trail (registered communication logs, call recordings, payment gateway records) before treating a complaint as one of impersonation rather than a routine renewal dispute.
Research cut-off date: September 2026. Readers should independently verify current IRDAI grievance procedures and the Bima Bharosa/Ombudsman framework before relying on this article, as processes may be updated.
References
Insurance Regulatory and Development Authority of India (Protection of Policyholders’ Interests, Operations and Allied Matters of Insurers) Regulations, 2024.
IRDAI Master Circular on Protection of Policyholders’ Interests, dated 5 September 2024.
Insurance Ombudsman Rules, 2017, as amended.
Consumer Protection Act, 2019.
Bharatiya Nyaya Sanhita, 2023, Sections 318 (cheating) and 319 (cheating by personation), subject to applicability on the facts.
Information Technology Act, 2000 (applicability subject to the statutory ingredients being satisfied on the facts).
Bima Bharosa — IRDAI Integrated Grievance Management Portal, https://bimabharosa.irdai.gov.in/.
National Cyber Crime Reporting Portal, https://cybercrime.gov.in/, and helpline 1930.
Author: Ananya Sutradhar
Ananya is a second-year law student (B.Com LL.B Hons) with a growing interest in contract law and cyber law. She currently interns at Lawvaani, writing on legal developments in technology and commercial law.