Statutory Notification (S.R.O)
GOVERNMENT OF PAKISTAN
SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN

Islamabad, the 1 st October, 2026

NOTIFICATION

S.R.O.1686(I)/2026.- The following draft of amendments to the Insurance Rules, 2017 proposed to be made by the Securities and Exchange Commission of Pakistan in exercise of the powers conferred by the section 167 of Insurance Ordinance, 2000, read with S.R.O. 708(I)/2009 dated 27th July 2009, are hereby published by the Securities and Exchange Commission of Pakistan for information of all persons likely to be affected thereby and notice is hereby given that objections and suggestions if any received to the Securities and Exchange Commission of Pakistan within thirty days of this notification will be taken into considerations, namely:-

DRAFT AMENDMENTS

In the aforesaid Rules,

(1) the rule 31 shall be omitted.

(2) in rule 41, sub rules 1,2 and 3, the following shall be substituted,

“41. Classes of insurance surveyors.— (1) For the purposes of section 114 of the Ordinance, the following shall be the main classes of insurance surveyors, namely :-

(a) Fire and property damage business;

(b) Marine, aviation and transport business;

(d) Agriculture insurance, including crop insurance;

(e) Engineering business, including machinery breakdown; and

(f) Miscellaneous business.

Provided that miscellaneous business shall be classified into the following sub-classes, namely: -;

(i) Liability business;

(ii) Workers compensation business;

(iii) Credit and surety ship business;

(iv) Accident and health business; and

(v) Others.”

2) A licence granted by the Commission under section 112 of the Ordinance shall specify the main class or classes of insurance surveyors for which the license is granted.

Provided that existing insurance surveyors who are already licensed shall apply for the licence of the main classes referred in sub-rule (1) on the expiry of their valid licence as on the commencement date of this notification.

Provided further that the insurance surveyors having licence for the miscellaneous class on the commencement date of this sub-rule shall at the time of renewal of their existing licence be issued a licence of miscellaneous business confirming that the applicant is eligible to undertake all the sub-classes stated at sub-clause (i) to (v) of clause (f) of sub-rule (1) above.

(3) A certificate of registration as an authorized surveying officer under section 113 of the Ordinance shall specify the main class or classes of insurance surveyors for which the certificate of registration is granted.

Provided that existing registered authorised surveying officers shall apply for the registration of the main classes referred in sub-rule (1) on the expiry of their valid registration as on the commencement date of this notification.

Provided further that the authorised surveying officers having registration for the miscellaneous class on the commencement date of this sub-rule shall at the time of renewal of their existing registration be issued a registration of miscellaneous business confirming that the applicant is eligible to undertake all the sub-classes stated at sub-clause (i) to (v) of clause (f) of sub-rule (1) above.”

(3) in rule 42,

(a) in clause (b), the following shall be substituted,

“for the purposes of clause (b) of that sub-section, the prescribed minimum level of professional indemnity insurance shall be Rs 1 million for any one event for the insurance surveyor with annual revenue of up to Rs. 10 million, and Rs. 3 million for any one event for the insurance surveyors with annual revenue of more than Rs. 10 million.

Provided that such insurance shall cover insurance surveyor and all its directors or officers who act as authorized surveying officers.

Provided further, the annual revenue shall be determined based on the financial statements of the company for the preceding financial year. Further, the insurance surveyors must consider the risk profile of their work and past experience and determine whether or not they should carry professional indemnity insurance in excess of the minimum requirement under this clause”.

(b) in clause (d), sub-clause (i), the following shall be substituted,

“At least two officers or directors who are individually certified as an authorised surveying officer for the class or classes of insurance surveyors in which a body corporate acts or proposes to act.

Provided that the existing insurance surveyors shall comply with this requirement within a period of 6 months after the coming into force of this requirement.

Provided further, that insurance surveyors shall undertake a reasonable number of survey jobs that are commensurate with their resources and the number of individual authorised insurance surveyors they appoint;”

“(iii) None of the director or officer, or employee of an insurance surveyor shall be appointed as director or officer, or employee in another insurance surveyor.

(iv) An insurance surveyor shall submit an annual return in the format prescribed in Annexure-VIII within 4 months of the close of the financial period to which it relates.

(v) The Code of Conduct:- Every insurance surveyor and the authorised surveying officer shall:

a) conduct themselves ethically and maintain integrity, honesty, and professionalism;

b) render decisions objectively, fairly, impartially, solely based on factual findings and free from personal interest or bias;

c) avoid situations where personal or financial interests, including those in other business advisory or consultancy services, could reasonably be perceived to impair their professional judgment. If a potential conflict of interest arises, the surveyor shall disclose it to the insurer promptly. The insurer shall assess the situation and determine appropriate actions, which may include continued engagement, reassignment, or additional oversight, based on the nature and materiality of the conflict;

d) only accept engagements in the class of business for which they hold a valid license;

e) conduct all assignments with due diligence, care, and skill, adhering to the standards expected in the profession, and stay updated on relevant professional developments;

f) protect all confidential information acquired in the course of their professional work. Disclosure of such information is permitted only with the express consent of the insurer or when legally mandated;

g) maintain a comprehensive and accurate record of all work conducted, including findings, photographic evidence, client information, policy details, and assessment reports. Such records shall be retained for a minimum period of five (5) years and shall be made available to the Commission, if required;

h) fully document all fees or other forms of compensation with receipts issued for all payments received in connection with survey work;

i) undertake survey jobs solely as an employee or agent of a single insurance surveyor, and shall not engage in such roles with multiple insurance surveyors simultaneously;

j) not be involved in the payment/ settlement of claims and salvage; and

k) promptly report any observed or suspected unethical, dishonest, or unlawful conduct, whether committed by themselves, colleagues, or any other regulated entity, to the Commission.

(vi) The Duties and Responsibilities:- The following shall, inter alia, be the duties and responsibilities of an insurance surveyor and authorized surveying officer:

a) conduct detailed surveys to assess the cause, extent, location, and amount of any loss incurred or claimed to be incurred under the insurance policy;

b) determine asset values at the time of loss, considering factors such as depreciation and salvage value to measure the extent of loss;

c) collect and document evidence, including photographs, video, and expert opinions, to support claim assessments;

d) validate repair estimates and cost calculations provided by claimants or vendors;

e) prepare clear and comprehensive survey reports detailing findings, claimable amounts, and settlement recommendations;

f) conduct thorough investigations for complex claims, including fire, machinery breakdowns, and liability disputes, etc;

g) comment on the admissibility of the claim and assess the liability of the insurer as per the policy terms and conditions;

h) ensure timely completion of survey reports as per the agreed timelines, subject to the provision of these rules, and submit a progress report where required;

i) employ the necessary tools and technologies to enhance the accuracy and efficiency of claim assessments;

j) establish procedures for internal review of quality control, including devising a policy for appointment of a quality review surveyor for high-value and complex claims. The quality control reviewer must be an authorized surveying officer with experience in the relevant class of insurance and independent of the actual claim assessment;

k) exercise reasonable and prudent oversight of all actions of the employees of the Company; and

l) communicate effectively with insurers, policyholders, and other parties as required.

vii) An insurance surveyor shall at all times comply with such other provisions of the Ordinance, the rules and regulations made thereunder and other orders, directions, and guidelines issued by the Commission from time to time, as are applicable to the insurance surveyors.”

(4) In rule 43,

(a) in sub rule 2, the following shall be substituted,

“2) An application for renewal of a licence for a class of insurance surveyors for which a licence is held shall, for the purposes of sub-section (4) of section 112 of the Ordinance, be made one month prior to the expiry of license and contain the following details in respect of the applicant, namely:—

a) its name;

b) the address of its registered office;

c) its postal address (if different);

d) a description of the business carried on by it (other than insurance surveying);

e) the names of shareholders holding more than ten per cent of the issued share capital;

f) the names of all officers or directors of the body corporate who are individually licensed as an insurance surveyor;

g) the names of other persons employed by the body corporate for the purpose of carrying out the business of an insurance surveyor;

h) the class of surveyors for which renewal of licence is sought; and

i) such other information as may be specified by the Commission in writing.”

(b) in sub rule 3, clause e, the following shall be substituted,

“ e) the insurance surveyor, its chief executive, any director or its officer registered as authorised surveying officers is not disqualified from acting as an insurance surveyor by virtue of non-compliance with any requirements contained in rule 42(d)(ii).”

“4) An application and declaration required under this rule shall be made in written form and the declaration shall be signed by at least two directors of the insurance surveyor.

5) An insurance surveyor shall inform the Commission of any change in the details required to be given under sub-rule (1) or (2) within three months of that change having taken effect and, such information shall be in written form and signed by not fewer than two directors of the insurance Surveyor and duly attested.”

(d) in sub rule 9, the following shall be substituted,

“(9) Where an application for renewal of a licence has been made to the Commission under sub-rule (2) above, but has not been decided by the Commission prior to the expiry date, the licence of the insurance surveyor shall continue to be valid until the application for renewal has been decided by the Commission.

Provided that the Commission shall decide the renewal of license of the insurance surveyor within a period of not more than thirty days from the expiry date of its licence.”

(5) in rule 44, the following shall be substituted,

“44. Authorised surveying officers — For the purposes of clause (c) of sub-section (3) of section 113 of Ordinance, any person entitled to apply to be registered as an authorised surveying officer shall possess the following qualifications, namely:-

a) The minimum educational qualification shall be a Bachelor’s Degree in any discipline from a recognized university.

Provided that for the sub-class of engineering insurance business, a bachelor’s degree in engineering, and for the sub-class of agriculture insurance business, a bachelor’s degree in agriculture from a recognized university shall be required. However, this proviso shall come into force upon the expiry of six months from the date of its enactment.

b) Complete a minimum of three years of practical experience in the class or classes of insurance surveyors for which registration is sought.

Provided, that this practical experience shall be obtained under the supervision of an insurance surveyor licensed by the commission with at least 2 authorized surveyors having more than five years of experience in class or classes of insurance surveyors for which the registration is sought or by having served in a senior management position in the claims or underwriting department of a non-life insurer. However, this proviso shall come into force upon the expiry of six months from the date of its enactment.

Provided further, for registration in any class or classes of insurance surveying business before the enactment of this proviso, the requirement of three years practical experience may be fulfilled through either obtained under the supervision of an insurance surveyor licensed at that time under the Ordinance or registered under the repealed Act, or obtained as an employee of an insurance Company.

c) A fresh applicant, seeking first-time registration as an authorized surveying officer obtains passing marks in a test for any or all classes of insurance

surveying business, which shall be undertaken from the professional institute approved by the Commission for the purposes of this sub-rule.

d) the person:

(i) is not a minor;

(ii) has not been found of unsound mind by a Court of competent jurisdiction

(iii) has not been found guilty within five years preceding the present date of criminal misappropriation or criminal breach of trust cheating or forgery or an abetment of or an attempt to commit any such offence by a Court of competent jurisdiction;

(iv) has not served any custodial sentence imposed by a Court of competent jurisdiction ending within five years preceding the present date;

(v) has not been found guilty by a Court of competent jurisdiction of any offence involving insurance;

(vi) has not been otherwise declared as disqualified by the Insurance Tribunal, other than for a term which had expired prior to the present date; and

(vii) is not an appointed agent (otherwise than in the sense that a person conducting a survey on the instructions of an insurance company may be described as that company’s agent) or an employee of an insurance company carrying on business in Pakistan.

Provided that, subject to the provisions of rule 46(A) sub-rule (1), an employee of an insurer performing the activities of the nature of insurance surveying for that insurer, shall also comply with clauses (a) and (b) of this rule.”

(6) in rule 45, the following shall be substituted,

“45. Training and Continuous Professional Development: (1) The directors and the chief executive officer of both first time and renewal applicants, and authorized surveying officers applying for renewal, must submit a Continuous Professional Development (CPD) Certificate as evidence of having completed 24 hours of training during the immediately preceding year, from an insurance institute(s), approved by the Commission, in the relevant subclasses.

(2) The CPD activities must focus on areas to cover legal and regulatory updates, including insurance and contract law, ethical and compliance requirements, advanced claims assessment techniques, emphasizing investigation, risk management, and technology modules, emerging risks, mitigation strategies or the use of digital tools in surveying, etc.”

(7) after rule 46, the following new rule 46A shall be inserted,

“46 A: Appointment of the Insurance surveyors: (1) It shall be mandatory for an insurer to appoint a licensed insurance surveyor in respect of general insurance claims reported by any policyholder where the claim amount exceeds Rs. 50,000 in the case of motor insurance, and Rs. 100,000 in the case of non-motor insurance.

Provided that an insurer or an insurance surveyor may engage a Technology Partner for claim assessment in case of technology-based insurance products.

(2) Every non-life insurer shall have a board-approved surveyor management policy. The surveyor management policy shall, at a minimum, provide:

a) The criteria and manner for the enlistment and de-listing of licensed insurance surveyors, along with the tenure of their enlistment.

b) The periodicity of review of the enlistment of licensed surveyors along with the performance review indicators, which shall, at a minimum, cover the adherence to timelines, quality of survey reports, professional conduct of the surveyor, etc.

c) The manner of allocation of survey assignments amongst the enlisted insurance surveyors based on the class of business, license eligibility, nature and quantum of loss, proximity to loss location, past performance and turnaround time and any other factor relevant to the allocation.

(3) In case of any claim by individual or corporate policyholders, the appointment of the insurance surveyor shall be made within seventy-two (72) hours from the time of claim intimation by the policyholder. Written notice of the appointment shall be provided to the policy holder including the role, duties and responsibilities of the surveyor, by letter, email, or any other electronic form immediately after the appointment of the surveyor.

(4) The policyholder may object in writing to the appointed surveyors on valid grounds such as conflict of interest, prior disputes, etc., within 48 hours of the intimation by the insurer. If justified, the insurer may consider replacing the insurance surveyor.

(5) In case expressly provided in the policy document, a licensed insurance surveyor may be appointed by any policyholder at its own expense. Such appointment shall be intimated to the insurer in writing, clearly specifying the name and license number of the appointed surveyor within seventy-two (72) hours from the time of claim intimation to the insurer. The Survey report shall be submitted to the insurer within the timelines prescribed under Rule 47, and the insurer shall consider the survey report by the insurance surveyor appointed by the policyholder while making the final decision on the claim. The insurer may consider the insurance surveyor appointed by the policyholder to fulfil the mandatory survey requirements under sub-rule (1), provided that such insurance surveyor is duly licensed and appointed in accordance with the terms of the insurance policy.

(6) The insurance surveyor or the insurer shall, within 7 days of the claim intimation, inform the insured/claimant of the essential documents and other requirements that the claimant should submit in support of the claim. Where documents are available in the public domain or with a public authority, the surveyor/insurer shall obtain them directly.

(7) The insurers are responsible for obtaining all necessary information and documentation from the claimant and providing it to the surveyors to enable them to complete their work within the specified timelines.

(8) The insurers must ensure that all due payments to insurance surveyors are made on time as per agreed terms, avoiding any long-outstanding dues to ensure independence of the insurance surveyors.”

(8) in rule 47,

(a) for sub-rule (2), the following shall be substituted,

“(2) Report given by an insurance surveyor shall be signed by a natural person who is, at the date of the report, registered as an authorized surveying officer for the class of insurance surveyors to which the loss being surveyed relates. The survey report shall be countersigned by the CEO or a director of the insurance surveyor. The authorized surveying officer and the insurance surveyor are jointly and severally responsible for the report. The report shall include the following, namely: —

a) a description of the property or interest which constitutes the subject matter of the survey report, sufficient to identify the property or interest;

b) the terms of reference given to the insurance surveyor by the person engaging him;

c) any instructions given to the insurance surveyor by the person engaging him, as to the facts to be assumed or other assumptions to be made by the insurance surveyor;

d) a description of the procedures carried out by the insurance surveyor in the conduct of the survey;

e) the opinion of the insurance surveyor on the matters contained in the term of reference; and

f) a declaration that neither the insurance surveyor, nor any director, employee, associate or partner of the insurance surveyor, nor any related party of any of those persons, has any interest directly or indirectly by way of insurance, ownership, agency commission, repairs, disposal of salvage, or in any other way whatsoever, other than as an insurance surveyor in the property or interest which constitutes the subject matter of the survey report.”

(b) for sub-rule (4), the following shall be substituted, “Every survey conducted by, and report given by, an insurance surveyor shall be conducted and given with due diligence and skill, and in good faith, and the report shall be finalized and shared as early as possible but within 15 days in case of motor claims, and within 30 days in case of non-motor claims of its appointment. Where, in special circumstances of the case, due to its nature or complexity, the surveyor may seek an extension, in any case not exceeding 6 months in aggregate from the insurer for submission of his report. However, for individual policies related to motor claims, such extension shall not exceed 30 days. In such cases, the insurance surveyor shall, in addition, submit an interim report to the insurer detailing the progress of the survey every 30 days from the due date, continuing until the final survey report is submitted.

Explanation:- Examples of the exceptional circumstances referred include: (a) complex insurance claims such as marine cargo, aviation, transit, contractors’ all risk, liability, engineering, and business interruption claims; (b) motor accidents involving extensive vehicle damage or third party damage that require longer time to estimate; (c) natural catastrophe losses and large event losses such as major floods or other significant disaster events; or (d) suspected fraud cases that require further investigation”

(c) after sub-rule (4) amended as aforesaid, the following new sub-rule (4a) shall be inserted, “(4a) In cases where the survey report is not finalized due to non-provision of documents by the insured, the surveyor may issue the final survey report independently based on the available documents on record, giving a minimum of 2 written reminders to the insured with a gap of 5 days. The insurance surveyor shall mention the documents or information not provided by the insured in the final survey report.”

(d) for sub-rule (5), the following shall be substituted, “(5) For the purposes of sub-section (1) of section 85 of the Ordinance, If the Commission has a reason to believe that a survey performed has not been performed

with due diligence or skill, or in good faith, or that it otherwise does not comply with the conditions of this rule, such that the report does not present a fair opinion on the matters contained in the terms of reference or the surveyor has given a false report or has grossly under-assessed or over-assessed a loss or has made an adjustment of loss in a grossly unjust manner, the Commission may direct the insurer to arrange an additional survey of the subject matter of the survey report to be performed by one or more licensed insurance surveyors who shall be approved by the Commission.”

(e) for sub-rule (6), the following shall be substituted, “(6) An additional survey under sub-rule (5) shall be performed at the expense of the insurer and a copy of the report on the additional survey shall be provided to the Commission and the policyholder.”

(9) after rule 47, the following new rule 47A shall be inserted, “47 A: Penalty for default in complying with or acting in contravention of these rules:- Except as otherwise provided in the Ordinance, any intermediary covered under Part XIII of the Ordinance who fails or refusesto comply with, or contravenes, any provisions of these rules, and, where the intermediary is a company, any director, or other officer of the company, who is knowingly a party to the default, shall be punishable with fine which may extend to one million rupees and, in the case of a continuing default, with an additional fine which may extend to ten thousand rupees for every day during which the default continues.

(10) In rule 61, the following shall be substituted, “61. Insurer’s duties when claim denied.- (1) An insurer shall, whenever a claim is denied, provide the policyholder with a written statement of reasons for denial of the claim. (2) Where refusal to pay a claim, in whole or in part, is based, in whole or in part, upon a survey report, the policyholder shall be provided with a copy of the survey report.

(11) after Annexure-VII, the following new Annexure-VIII shall be inserted,

“Annexure VIII [See Rule 42 (d) (vi)] Format of annual return to be submitted by Insurance surveyors

1. Name of the Surveyor:

2. Location of registered office:

3. Main districts of operations:

4. License No.:

5. Date of Expiry (DD-MM-YYYY):

6. Period of annual return:

7. Class-wise insurance surveys conducted during the last year, along with the following details:

Class of Insurance survey: Fire and property damage business
Sr. No.	Name of insurer	Amount of claim assessed	Number of surveys conducted	Fee Amount (Rs)

				Total

Class of Insurance survey: Marine, Aviation and Transport business
Sr. No.	Name of insurer	Amount of claim assessed	Number of surveys conducted	Fee Amount (Rs)


				Total

Class of Insurance survey: Motor business (to include own damage and third-party liability)
Sr. No.	Name of insurer	Amount of claim assessed	Number of surveys conducted	Fee Amount (Rs)


				Total

Class of Insurance survey: Miscellaneous business
Sr. No.	Name of insurer	Amount of claim assessed	Number of surveys conducted	Fee Amount (Rs)


				Total

8. Details of total revenue for the year

Sr. No.	Area of service	Name of the party/insurer	Fee Amount (Rs)
1.	Independent Insurance surveys
2.	Risk Assessment assignments
3.	Asset valuation
4.	Other Categories
	Total

9. Details of total revenue receivable from the insurers at the year-end

Sr. No.	Name of the insurer	Category of service (Independent insurance survey or other services)	Overdue for less than 90 days Amount (Rs)	Overdue for more than 90 days and less than 180 days Amount (Rs)	Overdue for more than 180 days Amount (Rs)	Total Receivable Amount (Rs)
1.
2.
3.

10. Details of authorized surveying officers and employees

Sr. No.	Classes of insurance surveying	Number of ASOs	No. of employees other than ASOs	Number of trainee students
1.
2.
3.
4.

11. Class- and insurer-wise details of pending survey reports not submitted within the stipulated time prescribed as per rule 47 (4)

Sr. No	Name of the insurer	Class of business	Number of delayed surveys	Reason for delay
1.
2.
3.
4.

”

[No.SY/SECP/8/13]

( Bilal Rasul )
Secretary to the Commission

Draft Amendments to the Insurance Rules, 2017