A legal notice has been issued demanding the immediate withdrawal of the Insurance Business Registration Fee (Amendment) Regulations, 2024, which introduced a significant increase in insurance company registration renewal fees. The notice also calls for the suspension of all activities related to the collection of the revised fees.
The notice was issued in the public interest on Monday (20 April) by Supreme Court lawyer Tanay Kumar Saha. It has been addressed to the Secretary of the Finance Division and the Chairman of the Insurance Development and Regulatory Authority.
The notice requests that the implementation of the amended regulations be suspended within seven days. It further demands that insurance companies be allowed to renew their licences under the provisions of the 2018 regulatory framework. It warns that if the directive is not complied with, 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, the 2018 regulations set the renewal fee at BDT 1.00 per thousand of gross premium. The 2024 amendment, however, has significantly revised the fee structure, resulting in a marked increase in costs for insurers.
For example, a company with a gross premium of BDT 100 crore previously paid a renewal fee of BDT 10 lakh under the 2018 system. Under the revised 2024 framework, this amount has increased to BDT 25 lakh. The notice also states that the fee is projected to rise further, reaching BDT 50 lakh by 2032.
Comparison of fee structures
| Category | 2018 Regulations | 2024 Amendment | Noted Impact |
|---|---|---|---|
| Fee calculation basis | BDT 1.00 per thousand gross premium | Revised upward under amendment | Higher overall cost burden |
| Example: BDT 100 crore premium | BDT 10 lakh | BDT 25 lakh | Around 150% increase |
| Projected fee by 2032 | Not specified | BDT 50 lakh | Up to 500% increase cited |
The legal notice argues that the increase ranges from approximately 150 per cent to 500 per cent, depending on projections, and describes it as excessive and inconsistent with established regulatory practice.
It is also noted that several insurance companies have already complied with the previous regulatory requirements by paying fees and completing licence renewals before 30 November 2025. The notice contends that applying the 2024 amendment to such completed transactions in 2026 contradicts the legal principle that laws should operate prospectively rather than retrospectively.
Furthermore, the notice claims that the increased financial burden will reduce the surplus funds of insurance companies. It argues that this may lead to lower policyholder bonuses and reduced dividends for shareholders, potentially affecting the overall financial stability of the insurance sector.
The notice further alleges that the revised fee structure effectively shifts administrative expenditure onto insurance operators and policyholders. It asserts that such costs should instead be borne by the Finance Division as part of regulatory administration, rather than being recovered through increased fees imposed on the industry.