As part of the National Insurance Commission’s (NAICOM) efforts to improve the insurance business in Nigeria and its recognition of the impact of technology in improving the insurance business and its penetration to the grassroots level, NAICOM released the Insurance Web Aggregators Operational Guidelines 2022 which is expected to serve as a framework for Insurance Web Aggregators.

From the date of commencement of the Guidelines, no one is allowed to function as a Web Aggregator unless he/she is licensed by NAICOM.[i] If anyone acts as a Web Aggregator without holding a valid Licence issued by the Commission, the Commission may in addition to any ongoing prosecution impose against such person penal action under the Act.[ii]

What is an Insurance Web Aggregator?

An Insurance Web Aggregator as defined in the Guidelines is a company registered under the Companies and Allied Matters Act (CAMA) and approved by NAICOM, which maintains or owns a website and avails information pertaining to insurance products and price/features comparisons of products of different insurers as well as offer leads to an Insurer.[iii]

Thus, an Insurance Web Aggregator must be registered under the CAMA and further approved by NAICOM to carry on a Web Aggregator’s business.

What are the criteria for grant of license as web aggregator for the grant/renewal of license of the web aggregator?

1. The Applicant must be registered with the Corporate Affairs Commission (CAC)
2. The Memorandum of Association of the Company shall have the business of Web Aggregation as its main objective.
3. The Applicant is not engaged in any other business other than the main objects of the Memorandum of Association
4. The Applicant shall have a minimum share capital of N5Miliion registered with CAC
5. The Applicant shall employ/designate a Principal Officer to manage the Company on full time
6. The Principal Officer shall possess a minimum qualification and must have a relevant University first degree qualification or its equivalent and IT-related qualification and/or relevant training experience
7. The Principal Officer must satisfy the conditions of FIT and PROPER Person criteria set out by NAICOM
8. The Applicant must have the necessary infrastructure, such as an adequate and conducive office, an adequate customer base, and necessary IT equipment to effectively discharge its duties.[iv]

Other things to note with respect to the application as a Web Aggregator include;

1. An Applicant seeking a grant of License as a Web Aggregator shall complete the Application form as prescribed under the Guidelines. This must be submitted alongside the requisite fees.
2. The Applicant shall submit the evidence of approval/No Objection Letter from NCC before securing the license to operate as Web Aggregator from the Commission.
3. The Commission may require an applicant to furnish any further information or clarification for the purpose of disposal of the application and thereafter, in regard to any other matter as may be deemed necessary by the Commission.
4. The Applicant shall appear before the Commission for personal representation in connection with the application.
5. In the event of a change of the name of any Insurer, the Web Aggregator partnering with such Insurer shall be apprised of the development.
6. A Licence issued shall be valid for a period of two years unless same is suspended or cancelled pursuant to the Guidelines.[v]

How Can One Apply for An Insurance Web Aggregator Operating License in Nigeria?

The registration of an insurance web aggregator is in three (3) stages;

Stage 1

At the first stage, the prospective insurance web aggregator (applicant) shall submit the following to NAICOM;

1. Copy of No Objection/approval issued by Nigerian Communications Commission (NCC)
2. Copy of letter of appointment issued to the Web Aggregator from named Insurer(s)/Broker(s)
3. Copy of Service Level Agreements (SLAs) with named Insurers/Brokers
4. Copy of Certificate of Incorporation issued by Corporate Affairs Commission (CAC)
5. Certified True Copy of Memorandum and Articles of Association of the Applicant
6. Copy of Board resolution in support of the partnership with named Insurers/Brokers
7. Payment of non-refundable application fee.[vi]

Upon the filing of the above documents, and if approved by NAICOM, the applicant may move to the second stage;

Stage 2

The following documents will be filed with NAICOM at this stage;

1. Organisational chart showing functional responsibilities
2. Board Resolution to commence a Web Aggregator operation
3.  Curriculum Vitae (CV) and Credentials of Principal Officers and Directors of the Web Aggregator Company
4. Principal place of business of the Web Aggregator and confirmation of place of hosting the website
5. Snapshots of contents of the proposed website along with proof of domain name registration.
6. Details of infrastructure including IT infrastructures available
7. Details and experiense of the platform authorised Verifiers
8. Copy of the Risk Management Framework
9. List of persons who have control over or responsibility for the website contents in relation to insurance web aggregation
10. A user I.D. and temporary password (with only view permission) to verify the aggregator’s website
11. Business plan with five years financials projection
12. Sworn declaration of non-disqualification by the proposed directors in line with Section 12(1) of the Insurance Act 2003
13.  Professional Indemnity Cover of not less than 20 Million limit of liability
14. Copy of Letter of appointment and acceptance of same of the proposed MD/CEO.[vii]

Upon satisfaction by NAICOM with the above, then the applicant may move to stage 3

Stage 3

The following shall be done in stage 3 of the application;

1. Physical verification of web aggregator head office address and IT infrastructure to be done by NAICOM
2. Payment of Licence fee by the applicant
3. Issuance of license by NAICOM.[viii]

Conclusion

This article has simplified how to get an insurance web aggregator license in Nigeria. Aside from what is stated in the article, there are certain things that an applicant for a Web Aggregator Insurance Licence must be aware of such as Code of Conduct, Mode of Operations, certain Obligations, and Restrictions. Thus, it is best to consult a legal practitioner who is an expert in insurance business in Nigeria to avoid problems later on.

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[i] Reg 14.2.2 of the Insurance Web Aggregators Operational Guidelines

[ii] ibid

[iii] Reg. 2.0

[iv] Reg 6.1

[v] Reg 6.0

[vi] Reg 4.3

[vii] ibid

[viii] ibid

Written by Rodiyyah Bashir for The Trusted Advisors

Email us: info@trustedadvisorslaw.com

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