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Banking and Insurance - Laws and Practice · Functions in Insurance and Compliance related thereto (Part II)

Surveyors, Loss Assessors and Insurance Intermediaries

Updated 11 October 2026 · Fact-checked

A surveyor or loss assessor is a licensed professional who inspects and assesses a loss for a general insurer. Section 64UM of the Insurance Act, 1938 requires prescribed qualifications and membership of the Indian Institute of Insurance Surveyors and Loss Assessors. Insurers must obtain a licensed surveyor's report for claims at or above the prescribed amount.

Understand Surveyors, Loss Assessors and Intermediaries

When you make a general insurance claim, the insurer needs an independent view of what was lost and how much it is worth. A surveyor or loss assessor gives that view. The insurer then decides the claim with the report in hand.

Section 64UM of the Insurance Act, 1938 controls who may do this work. A person must hold the academic qualifications specified in the regulations. The person must also be a member of the Indian Institute of Insurance Surveyors and Loss Assessors. For a firm or company, every partner, director or other person who may be called upon to survey or assess a loss must meet both conditions.

Every surveyor and loss assessor must follow the code of conduct set by regulations. This covers duties, responsibilities and other professional requirements. Surveyors who were licensed before the 2015 amendment could continue for a period specified in the regulations. They had to meet the qualification and membership requirements within the period notified by the Authority. Otherwise they were automatically disqualified.

The Act does not make a surveyor's report final. The insurer may pay or settle a claim at an amount different from the assessed amount. The Authority can also call for an independent report from another approved surveyor, at the insurer's cost, and can direct how the claim is settled.

Intermediaries are a wider group. They include agents, brokers, third party administrators and similar persons who help distribute insurance or service policies. The Act's Section 64F also shows that surveyors and loss assessors, agents and third party administrators are represented on the General Insurance Council's Executive Committee through nominations by the Authority. Rules for intermediaries are in the Act and the Authority's regulations, so state them in general terms unless you are sure of the exact provision.

Key rules to remember

Eligibility to act (Section 64UM(1))
Surveyor or loss assessor = specified academic qualifications + membership of the Indian Institute of Insurance Surveyors and Loss Assessors
Both conditions are needed. For a firm or company, every partner, director or other person who may make a survey or assess a loss must satisfy both.
Mandatory report (Section 64UM(4))
Claim ≥ amount specified in regulations → insurer must obtain a report from an approved surveyor or loss assessor before admitting or settling it
Applies to a loss occurring in India and payable or settled in India. The Authority may direct otherwise.
Insurer's freedom (proviso to Section 64UM(4))
Insurer may pay or settle at an amount different from the surveyor's assessment
The report is mandatory, but it does not bind the insurer's final figure.
Authority's independent report (Section 64UM(5) and (6))
Authority calls independent report → cost borne by insurer → Authority may direct settlement higher or lower
The insurer must comply. A lower figure after payment is not enforced if recovery would cause undue hardship to the insured.
Fees (Section 64UM(7))
Fee for surveying, verifying or reporting on a claim → only to an approved surveyor or loss assessor
Section 64UM(8) allows another person for claims below the specified amount if employing an approved surveyor would be disproportionately expensive.
Exemption (Section 64UM(10))
Authority may exempt a class of claims by order
Grounds: it is customary to use someone other than a licensed surveyor, or a survey is not practicable.

How to solve Surveyors, Loss Assessors and Intermediaries questions

Use this order for any question on surveyors, loss assessors or intermediaries. It keeps your answer in the provision, analysis, conclusion format.

  1. 1Identify the person involved: surveyor or loss assessor, or another intermediary such as an agent or third party administrator.
  2. 2State the rule: for surveyors, the qualification and membership requirements of Section 64UM(1), plus the code of conduct in 64UM(2).
  3. 3Check the claim amount against the amount specified in the regulations. This decides whether a report is mandatory (64UM(4)) or whether 64UM(8) allows another person.
  4. 4Check the status of the person: newly licensed, pre-2015 licensee within the notified period, or disqualified under 64UM(3).
  5. 5Look for Authority involvement: independent report, direction to settle, or exemption of a class of claims.
  6. 6Apply the rule to the facts in two or three sentences, using the actual names and amounts.
  7. 7Conclude clearly, for example whether the claim could be settled, whether the fee was lawful, or what the insurer should do. Add a compliance or drafting point if asked.

Quickest way: Three-check method for surveyor questions

When to use it: Use when time is short and the question asks whether an insurer or surveyor acted correctly.

  1. Check the person: qualified, member of the Institute, and for a firm, all relevant partners or directors.
  2. Check the claim size against the amount in the regulations: at or above means a licensed report is mandatory.
  3. Check the authority: has the insurer kept its right to settle differently, and has the Authority directed anything?
  4. Write the conclusion in one line and cite Section 64UM.

Common mistakes in Surveyors, Loss Assessors and Intermediaries

  • Saying the insurer must pay exactly the amount the surveyor assesses.

    Students assume the report is binding because it is mandatory.

    Fix: State the proviso to 64UM(4): the insurer may pay or settle at a different amount.

  • Stating a fixed rupee limit above which a surveyor is needed.

    Students remember a figure from a circular or a coaching note.

    Fix: Write that the Act refers to an amount specified in the regulations. Quote a figure only if the question supplies it.

  • Treating membership of the Institute as the only requirement.

    Clause (b) is easier to remember than clause (a).

    Fix: Always give both: specified academic qualifications and membership of the Indian Institute of Insurance Surveyors and Loss Assessors.

  • Forgetting that every partner or director of a firm or company must qualify.

    Students think the entity itself is licensed and nothing more is needed.

    Fix: Quote the proviso to 64UM(1): all partners, directors or other persons who may make a survey or assess a loss must satisfy both clauses.

  • Saying the insurer can recover any excess paid if the Authority directs a lower figure.

    Students read only the main direction power.

    Fix: Add the provisos to 64UM(6): the insurer need only take reasonable, proportionate steps, and no lower sum is directed if recovery would cause undue hardship to the insured.

Worked examples

Example 1

Surya General Insurance Ltd receives a fire claim from a Pune factory, and the claim is at or above the amount specified in the regulations. The insurer wants to settle it using its own claims officer's assessment, without a licensed surveyor. Advise.

Show the solution
  1. Provision: Section 64UM(4) says a claim equal to or above the specified amount, for a loss in India payable in India, cannot be admitted or settled unless the insurer has obtained a report from an approved surveyor or loss assessor.
  2. Analysis: the facts say the claim is at or above the specified amount, and the loss is in India. The claims officer is not a licensed surveyor.
  3. Exceptions: the Authority may direct otherwise, or exempt a class of claims under 64UM(10). Nothing in the facts shows either.
  4. Further point: under 64UM(7) the insurer should not pay a fee for surveying or reporting to anyone who is not an approved surveyor or loss assessor.
  5. Conclusion: the insurer must appoint an approved surveyor or loss assessor and obtain the report before settling. It may still settle at a different amount from the one assessed.

Answer: Surya General cannot settle on its own officer's assessment. It must first obtain a report from an approved surveyor or loss assessor under Section 64UM(4). It keeps the right to settle at a different amount.

Example 2

Mehta Loss Assessors LLP is a firm with three partners. Two partners are members of the Indian Institute of Insurance Surveyors and Loss Assessors and hold the specified qualifications. The third, who also handles surveys, holds the qualifications but is not a member. Can the firm act as a loss assessor for general insurance?

Show the solution
  1. Provision: Section 64UM(1) requires qualifications under clause (a) and membership under clause (b).
  2. Proviso: for a firm or company, all partners, directors or other persons who may be called upon to make a survey or assess a loss must fulfil both clauses.
  3. Analysis: the third partner handles surveys, so is covered by the proviso, but lacks membership.
  4. Conclusion: the firm does not satisfy the requirement while that partner is non-compliant.
  5. Compliance point: the third partner should obtain membership, or should not be called upon to survey or assess losses.

Answer: No. The third partner does not meet clause (b), and the proviso to 64UM(1) requires every partner who may survey or assess a loss to meet both clauses. The firm can act only after this is cured.

Exam tips

  • Quote Section 64UM sub-section numbers: (1) eligibility, (2) code of conduct, (3) pre-2015 licensees, (4) mandatory report, (5) and (6) Authority's powers, (7) fees, (8) and (9) small claims, (10) exemption.
  • In case questions, first compare the claim amount with the specified amount. Do not invent a figure.
  • Mention the insurer's right to settle at a different amount whenever you discuss the surveyor's report.
  • For intermediary questions, link to the General Insurance Council: Section 64F provides for nominated representatives of agents, third party administrators, surveyors and loss assessors and policyholders on its Executive Committee.
  • Close each answer with a clear conclusion and one practical compliance step.

Practice questions from Functions in Insurance and Compliance related thereto (Part II)

Surveyors, Loss Assessors and Intermediaries: frequently asked questions

What is the difference between a surveyor and a loss assessor?

The Insurance Act, 1938 treats them together in Section 64UM and applies the same qualification, membership and conduct rules to both. In practice, a surveyor inspects the loss and its cause, and a loss assessor works out the amount payable. In exams, say both are covered by the same section.

Who can act as a surveyor or loss assessor under Section 64UM?

A person with the academic qualifications specified in the regulations who is also a member of the Indian Institute of Insurance Surveyors and Loss Assessors. For a firm or company, every partner, director or other person who may make a survey or assess a loss must meet both conditions.

Is a surveyor's report compulsory for every claim?

No. It is mandatory for claims equal to or above the amount specified in the regulations. For smaller claims, the insurer may use another person if an approved surveyor would be disproportionately expensive, but the Authority may direct that a claim be reported on by an approved surveyor.

Can the insurer settle a claim for a different amount from the surveyor's assessment?

Yes. The proviso to Section 64UM(4) preserves the insurer's right to pay or settle at a different amount. The Authority can, however, call for an independent report and direct settlement at a higher or lower figure, and the insurer must comply.