What compliance documents should an employer maintain for group health insurance?

An employer running a group health insurance policy in India should maintain six categories of documents: the policy contract and endorsements, employee enrolment records, claims and dispute logs, TPA and broker agreements, tax and GST records, and any grievance filings or Ombudsman correspondence. Retention periods for these documents range from 3 to 8 years depending on the document type, and complete records are essential for renewal negotiations, tax audits, and any regulatory review.

What policy documents should the employer keep?

The policy contract file should hold:

• Signed proposal form submitted at policy inception, with all declarations by the employer.
• Policy schedule and certificate of insurance issued by the insurer, listing the sum insured, riders, exclusions, and policy period.
• Master policy wording covering terms and conditions, definitions, sub-limits, and exclusions.
• Endorsement letters for any mid-year changes such as adding new members, updating dependants, or adjusting sum insured.
• Premium payment receipts and GST invoices from the insurer.
• Renewal correspondence and prior year policies going back at least 3 years.

These documents are the foundation of any dispute resolution, and missing endorsements can cause coverage confusion for individual employees at claim time.

What employee enrolment records should be kept?

Enrolment records should include:

• Employee master list shared with the insurer, updated at each addition or deletion.
• Dependant addition forms for spouse, children, and parents where applicable.
• Nomination forms naming beneficiaries for each covered employee.
• Health cards issued log, with issue date and any replacements.
• Onboarding communication shared with new joiners, covering policy terms and claim process.

These records are essential for reconciling insurer premium invoices and for demonstrating that employees were duly informed of their cover.

What claims-related documents should be maintained?

The claims log should contain:

• Claim intimation register with claim number, employee name, date of admission, and estimated cost.
• Cashless approval letters from the TPA, with approval amounts.
• Discharge summaries and hospital bills for major claims.
• Reimbursement claim submissions and insurer settlement letters.
• Denial letters and grievance correspondence for any disputed claims.

Aggregated claim data feeds directly into the renewal loss ratio calculation, and detailed records help the broker push back on any insurer claim that specific incidents are outside cover.

What contracts and service agreements should be filed?

Three service agreements typically apply:

• Broker service agreement: Where the employer works with a licensed insurance broker, the appointment letter and service scope should be on file.
• TPA service standards: The service level agreement or reference document from the TPA, covering cashless approval timelines, helpline hours, and escalation contacts.
• Insurer contact escalation matrix: Names, roles, and contact details for the insurer's grievance officer, senior claims officer, and account manager for the employer.

What tax and GST records apply?

Group health insurance carries specific tax and GST implications:

• GST invoices from the insurer at 18% on group premium, dated and matching the premium payment.
• Section 37(1) deduction record in the employer's tax file, showing the premium as a business expense.
• Perquisite exclusion documentation demonstrating that the employer-paid premium was correctly treated as exempt under Section 17(2) of the Income Tax Act.
• Input Tax Credit denial note reflecting that ITC is blocked under Section 17(5)(b) of the CGST Act for employee health insurance.

These records support the employer's tax filing position and are needed in the event of any tax scrutiny.

What grievance and dispute records should be retained?

Any grievance filed under the IRDAI process should be documented with:

• Initial complaint to the insurer's grievance officer.
• Escalation to Bima Bharosa if applicable.
• Ombudsman filings and awards, if the case reached that stage.
• Any subsequent legal or consumer court filings.

What retention periods apply?

Retention periods vary by document type:

• Policy contracts and endorsements: 8 years from policy expiry.
• Claims documents: 8 years from claim closure.
• Tax and GST records: 8 years from the end of the relevant financial year.
• Employee enrolment records: as long as the employee remains covered, plus 3 years from cessation.
• Grievance and Ombudsman records: 5 years from case closure.

These are practical retention windows that match tax audit, insurance dispute, and IRDAI regulatory considerations.

How Plum approaches this

Plum maintains the policy contract, endorsement, claims, and premium records for Plum-managed group policies through its platform, so employers do not have to hold every document separately in local files. Across Plum's group book, claims NPS runs at 79 and cashless pre-authorisation clears in a median of 45 minutes, both metrics that Plum shares with employers alongside compliance-ready reports at renewal. Plum places group cover from a minimum of 7 employees, working with partner insurers including ICICI Lombard, HDFC ERGO, Bajaj Allianz, Star Health, Niva Bupa, and Aditya Birla Health Insurance, and provides employers with document access across the full engagement.

Frequently asked questions

Are digital records acceptable for compliance?

Yes. Digital copies of policy documents, invoices, and claim records are accepted under the Information Technology Act, 2000 and IRDAI guidelines, provided they can be produced when required.

What happens if the employer cannot produce records at a tax audit?

Missing records for GST invoices or Section 37(1) deductions can result in disallowance of the expense claim, triggering additional tax liability and penalties.

Should the employer keep documents beyond the retention period?

Retention periods are minimums. Employers with legal disputes still open or pending audits should hold documents until those matters close.

Who owns the claim documents: the employer or the insurer?

The insurer holds original claim documents. The employer and employee typically retain copies. Certified copies are available from the insurer on request.

Does the broker maintain compliance records too?

Yes. The broker maintains parallel records under IRDAI (Insurance Brokers) Regulations, 2018. The employer's records complement rather than replace the broker's file.

Are compliance requirements different for group and retail policies?

The IRDAI framework applies uniformly. Group policies have additional records around employee lists and dependant enrolment that individual policies do not require.