Submission of Investor Communication

Date: October 21, 2026 BSE Limited, The Calcutta Stock Exchange Limited 1st Floor, P.J. Towers, 7, Lyons Range, Dalal Street, Fort, Dalhousie, Mumbai - 400 001. Kolkata 700 001 Scrip Code: 526530 Scrip Code: 029404 Sub: Investor Communication. Dear Sir/Madam, Pursuant to the provisions of Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, please find enclosed herewith the Investor Communication disseminated to the shareholders on October 21, 2026. The same is available on the website of the Company at https://www.iirmholdings.in/investor/other-information- disclosures/ Kindly take the same on record. Thank you. Yours faithfully, For IIRM Holdings India Limited Vurakaranam Ramakrishna Chairman and Managing Director DIN:00700881 Encl: as above IIRM HOLDINGS INDIA LIMITED SHAREHOLDER COMMUNICATION IRDAI Distribution Reforms and the Outlook for IIRM Holdings 2O0c OtoCbTeOrB 2E1R, 22002266 Dear Shareholder, On behalf of the Board and the entire team at IIRM Holdings India Limited, I extend warm greetings and best wishes to you and your family for the festive season. We are also pleased to share that the Company is progressing with the listing of its equity shares on the National Stock Exchange of India Limited on Thursday, 22 October 2026. This is another important milestone in the evolution of IIRM Holdings and reflects our commitment to building a larger, stronger and more vibrant institution. EXECUTIVE SUMMARY The current IRDAI document is consultation paper for CONSULTATION, NOT FINAL REGULATION public comments. Stakeholder submissions will be considered before a further draft and final regulations. In the Company’s assessment, a material new framework may take effect from around 1 April 2027. LIKELY TIMING FY 2026-27 is therefore unlikely to see a material impact or slightly earlier if the process gets done faster. Fintech, Aggregators, Motor Dealerships, Bancassurance, NBFC may face larger reductions than IMPACT WILL VARY BY CHANNEL other broker models due to Product mix concentration of high brokerage lines. Exposure to New Motor sales, Retail life and Retail health is negligible. Limited impact on consolidated IIRM IS COMPARATIVELY WELL POSITIONED EBITDA is expected in the current financial year. Top line Retail revenue could decline by 10% to 15% however this is very low EBITDA vertical. The approximately ₹150 crore fund raise, and a GROWTH STRATEGY REMAINS INTACT pipeline of multiple acquisition opportunities support expansion over the next 12 to 24 months. OUR POSITION We support urgent action on mis selling, distribution cost, low penetration and insurer operating expenses, while advocating a balanced framework that recognises independent advice, servicing and claims support provided by Insurance Brokers. IIRM HOLDINGS | SHAREHOLDER COMMUNICATION 1 IIRM HOLDINGS INDIA LIMITED WHY REFORM IS BEING CONSIDERED IRDAI has identified several issues requiring urgent attention across the insurance sector: • Mis-selling and compulsory or inappropriate bundling of insurance products • The overall cost of insurance distribution • Insufficient insurance penetration despite industry growth • High operating and management expenses of insurance companies • Inadequate transparency in certain distribution arrangements • The need to align incentives with suitability, persistency, service quality and claims outcomes IIRM VIEW These are genuine industry issues requiring timely action. Higher penetration, better customer outcomes, transparency and accountability are essential for sustainable growth. This should also be coupled with viable distribution incomes for the distributors. CONSULTATION PROCESS AND EXPECTED TIMELINE The documents under discussion are consultation documents. The regulator has been engaging insurers, intermediaries and other stakeholders and examining differing viewpoints and the practical and economic implications of the proposals. Following this phase, we expect IRDAI to review stakeholder suggestions and issue a further draft for comments before final regulations are notified. Our present assessment is that a new material framework may become effective from around 1 April 2027. This is the Company’s assessment and is not a date announced or confirmed by IRDAI. EVOLUTION OF COMMISSION REGULATION 2003-2023 2023 CURRENT REVIEW Product- and segment-level Shift from micro controls to Assessment of whether the flexible commission ceilings broader expenses-of-management framework delivered affordability, discipline penetration, efficiency and customer outcomes The broking industry grew under the earlier cap regime and continued to develop after the 2023 changes. We believe it will continue to grow under a balanced framework because commercial and institutional clients require independent advice, comparison, structuring, servicing and claims support. FY 2026-27 OUTLOOK We do not at present expect the consultation process to have a material impact on the Company during the financial year ending 31 March 2027. The first nine months are expected to operate substantially under the existing framework, and it is possible that the fourth quarter may also pass without material change. IIRM HOLDINGS | SHAREHOLDER COMMUNICATION 2 IIRM HOLDINGS INDIA LIMITED HOW THE PROPOSED CAPS MAY AFFECT DISTRIBUTION MODELS Brokers provide substantially more than policy procurement. Their work includes risk assessment, policy design, insurer comparison, negotiation, policy-document verification, servicing, renewals and claims advocacy. CHANNEL INDICATIVE EFFECT RATIONALE Life and retail health commissions, together with FINTECH & Potentially high volume-linked incentives, are proposed to AGGREGATORS reduce sharply. MOTOR OEM / NEW New vehicles and mandatory motor covers may Potentially high VEHICLE carry nil or materially lower remuneration. Lending-linked distribution, compulsory BANKS & NBFCs Significant bundling and volume-linked staff incentives are a major focus. Many have not received peak remuneration and operate with leaner cost structures. Actual OTHER BROKERS Generally, more measured impact depends on business mix and size of operations. EXPECTED IMPACT ON IIRM HOLDINGS CONSOLIDATED EBITDA RETAIL-LINE REVENUE LIMITED IMPACT 10%-15% DECLINE Impact presently not expected - future impact could Potential decline in thin-margin lines could be off be mitigated with muti line product mix set with planned acquisitions to grow the top line. The Group’s principal focus areas are: Property & engineering Group health & benefits Reinsurance Wellness Shared services Specialty lines International operations Commercial insurance The Group’s diversified revenue streams provide resilience against pressure in selected segments. Even if the proposals are implemented without material modification, the group is well equipped with alternate growth strategies to overcome these revenue drops. IIRM HOLDINGS | SHAREHOLDER COMMUNICATION 3 IIRM HOLDINGS INDIA LIMITED INORGANIC GROWTH AND DEPLOYMENT OF CAPITAL The Company has initiated an active inorganic growth programme and has recently concluded a fund raise of approximately ₹150 crore to support acquisitions and strategic expansion. MULTIPLE ₹150 CR 12-24 MONTHS ENTITITES CAPITAL RAISED STRATEGIC HORIZON For acquisitions and expansion ACTIVE PIPELINE Expected footprint enlargement Potential acquisitions under review Subject to satisfactory due diligence, valuation, documentation, regulatory approvals and other customary conditions, the Company intends to progress suitable transactions over the coming months, ideally before the end of the current financial year. Strategic benefits expected from the acquisition programme ✓ Expand geographic and customer footprint ✓ Broaden commercial, specialty and retail capabilities ✓ Add specialist expertise and distribution capacity ✓ Improve operating scale and cost efficiency ✓ Create cross-selling opportunities across Group ✓ Support international and [Showing first 8,000 characters — download PDF for full document]