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Insurance · Reinsurers · Brokers · MGAs · Insurtech

Protect the policyholder.
Satisfy the regulator.

Penetration testing and adversary simulation for insurers, reinsurers, brokers, MGAs and insurtech firms. IRDAI Information & Cybersecurity Guidelines 2023, NAIC Insurance Data Security Model Law, EU Insurance Distribution Directive, GDPR / DPDP Act 2023, ISO 27001:2022, SOC 2 Type 2 and NIST CSF 2.0 mapped per finding.

Pain points insurance CISOs raise on the scoping call

PII volume across the lifecycle

A single auto or health policy file holds name, address, government ID, date of birth, banking instrument, medical history, vehicle registration, claims history and beneficiary details — multiplied across millions of in-force policies and claims. Breach impact under DPDP Act 2023, GDPR Art. 33 and US state insurance commissioner notification rules is correspondingly severe.

Claims-system manipulation and fraud

Claims platforms combine high-value workflow logic, payout instruments and third-party agent access. Business-logic flaws — reserve manipulation, FNOL injection, payout-bank-account change without re-authentication, document-upload bypass — drive measurable underwriting and fraud losses, not just regulatory risk.

Broker portals as credential-stuffing magnets

Broker and agent extranets attract credential stuffing using credentials leaked from unrelated breaches, MFA bypass via SMS interception or push-notification fatigue, and IDOR / BOLA breaks that let one broker enumerate another broker's book or a customer's policy data. The dominant insurance attack surface in the public record.

Third-party agent and surveyor risk

Loss adjusters, surveyors, IMFs, web aggregators and corporate agents all need access to subsets of policy and claims data. The IRDAI 2023 guidelines, NAIC Model Law and the EU IDD all impose specific oversight obligations on these relationships. Account takeover of an agent is a common pivot into the insurer.

Sanctions screening and AML overlay

Insurance underwriting and payout flows hit the same OFAC, EU and UN sanctions lists as banking. Screening-bypass vulnerabilities (Unicode normalisation, transliteration, partial-name matching gaps) on the underwriting and claims flows expose the insurer to enforcement under the OFAC Insurance Industry guidance and equivalent EU regimes.

Legacy core systems on modern perimeters

Guidewire, Duck Creek, Insurity, Sapiens, Majesco and bespoke COBOL / mainframe cores frequently sit behind modern API gateways and customer apps. The integration layer is where authorisation breaks accumulate — between claims, policy admin, billing and reinsurance ledgers — and where the highest-impact findings live.

Compliance frameworks the engagement maps to

IRDAI Information & Cybersecurity Guidelines 2023

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Issued 24 April 2023, supersedes the 2017 guidelines. Applies to all insurers, reinsurers, intermediaries and ancillary service providers in India. Mandates annual VAPT of critical information assets, additional VAPT after major change, annual application security assessment for every internet-exposed application, quarterly vulnerability assessments, board-approved policy reviewed annually, CISO reporting to the board, and incident reporting to IRDAI and CERT-In within stipulated windows.

NAIC Insurance Data Security Model Law (#668)

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Adopted by the NAIC in 2017; enacted in 23+ US states by 2026. Requires a written information security programme based on risk assessment, designated qualified individual, periodic risk assessments, encryption of nonpublic information in transit and at rest, MFA for nonpublic information access, annual penetration testing, biannual vulnerability assessment, third-party service-provider oversight, 72-hour cybersecurity event reporting and an annual compliance certification.

EU Insurance Distribution Directive (Directive (EU) 2016/97)

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Applies to insurance and reinsurance distribution across the EU since 1 October 2018. IDD-aligned product oversight and governance (POG) requirements, conduct-of-business standards for distributors, professional and organisational requirements, plus the IDD-supporting Commission Delegated Regulation (EU) 2017/2358 on POG and (EU) 2017/2359 on conduct-of-business and conflicts of interest. Cybersecurity obligations flow through the operational-resilience expectations of national competent authorities and the DORA framework for in-scope entities.

EU GDPR + India DPDP Act 2023

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Articles 5, 25, 32, 33, 35 of GDPR for security of processing, privacy by design and default, breach notification at 72 hours and DPIA where required. DPDP Act 2023 §8 (reasonable security safeguards), §9 (children's data, relevant to motor and health policies), §32 (significant data fiduciary obligations) and the DPDP Rules 2025 for incident reporting. Insurance is consistently in scope as a significant data fiduciary.

ISO/IEC 27001:2022 + ISO/IEC 27002:2022

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International ISMS standard. 93 controls in Annex A (down from 114 in 2013), reorganised into four themes — organisational, people, physical, technological. Insurers and reinsurers across India, EU, UK and the GCC routinely require ISO 27001:2022 certification at the entity level or for specific business units. The engagement provides per-finding mapping to the relevant Annex A controls.

AICPA SOC 2 Trust Services Criteria

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Security category mandatory, with Availability and Confidentiality commonly added for insurance carriers and insurtech firms selling into US enterprise. CC7.1 (vulnerability identification), CC7.2 (anomaly monitoring) and CC8.1 (change management) are the relevant Common Criteria for the pentest evidence. Engagement reports include the SOC 2 control mapping appendix and the Letter of Attestation for the auditor.

NIST Cybersecurity Framework 2.0

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February 2024 release. Six core functions — Govern, Identify, Protect, Detect, Respond, Recover — with category and sub-category controls used by US insurance departments and increasingly cited in NAIC, IAIS and Lloyd's market-wide expectations. Findings include a NIST CSF 2.0 sub-category mapping appendix.

Sample attack scenarios exercised

Three scenarios commonly run for an insurance engagement. Each maps to public-record incident archetypes against insurers, reinsurers and broker platforms over the last five years.

Scenario 1 — Broker portal credential stuffing into book-of-business enumeration
Realistic-volume credential-stuffing against the broker login from a rotating proxy pool, using credential lists derived from unrelated breaches. Tests rate-limit thresholds, captcha rotation, device-fingerprint logic and the MFA enrolment / recovery flow for bypass. Post-authentication, exercises BOLA against the broker's book of business — does a single compromised broker session enumerate policies belonging to other brokers, or customer data outside the broker's appointment scope? Mirrors the dominant insurance ATO pattern in the public record.
Scenario 2 — Claims system manipulation across the FNOL-to-payout lifecycle
Authenticated testing as customer, agent, surveyor / loss adjuster and claims handler. FNOL intake injection (special-character handling, document-upload polyglots, MIME confusion), claim-status enumeration across customer accounts, reserve and claim-amount manipulation, payout-bank-account change without re-authentication, and downstream impact on the integrated policy administration system and the reinsurance ceding ledger. OWASP ASVS L2 V11 business-logic depth applied across the workflow.
Scenario 3 — Third-party agent account takeover and post-ATO data exfiltration
Simulated takeover of a corporate-agent, IMF or web-aggregator account through credential reuse, OAuth-token theft via partner-integration weakness, or session fixation against legacy SAML. Post-ATO actions exercise the IRDAI / NAIC / IDD third-party oversight expectations — quote manipulation, policy-data extraction across the agent's customer base, beneficiary-detail change for in-force life policies, and pivot toward the core policy administration system through the agent-API integration layer.

Case study

Redacted reference — available under NDA

Mid-market general insurer, motor + health + property lines, India HQ with reinsurance ceding into Lloyd's and continental European reinsurers. Ten-week engagement covering the customer mobile app, broker portal, corporate-agent extranet, claims-platform (Guidewire ClaimCenter integration), policy administration core, reinsurance bordereaux feed and the AWS control plane. Mapped to IRDAI Information & Cybersecurity Guidelines 2023, ISO 27001:2022 Annex A, DPDP Act 2023, and the NIST CSF 2.0 sub-categories required by the cedents.

Outcome: Two Critical broker-portal BOLA findings closed before the IRDAI inspection window, claims-platform payout-bank-account-change flow hardened with step-up authentication, third-party agent ATO scenario validated against the SOC playbook, reinsurance bordereaux ingest authorisation gap remediated, and the AWS IAM privilege-path graph reduced from 47 escalation paths to 4. IRDAI inspection closed with no major findings; SOC 2 Type 2 cycle started on the back of the same evidence pack.

Full redacted report and reference call available under mutual NDA. Request via the scoping form →

Related work

Frequently asked questions

What does the IRDAI Information & Cybersecurity Guidelines 2023 actually require from a pentest perspective?+

The IRDAI Information and Cybersecurity Guidelines 2023, issued on 24 April 2023, supersede the 2017 guidelines and apply to all insurers, reinsurers, intermediaries (brokers, corporate agents, web aggregators, IMFs) and ancillary service providers in India. The document mandates an annual VAPT for all critical information assets, additional VAPT after any major change, a separate annual application security assessment for every internet-exposed application, quarterly vulnerability assessments, a board-approved Information & Cybersecurity Policy reviewed annually, a Chief Information Security Officer reporting to the board, and incident reporting to the IRDAI and CERT-In within the stipulated windows. The engagement maps every test case to the relevant clause and produces the artefact bundle the IRDAI inspection team asks for: VAPT report, remediation tracker, retest evidence, CISO sign-off and the board-minute confirmation of review.

We sell into the US market. How does the NAIC Insurance Data Security Model Law affect us?+

The NAIC Insurance Data Security Model Law (Model #668), originally adopted in 2017, has been enacted in 23+ US states as of 2026 — including New York (under 23 NYCRR Part 500 which preceded the Model Law and remains operative), Ohio, South Carolina, Michigan, Mississippi, Alabama, Connecticut, Delaware, Indiana, Louisiana, Maine, Minnesota, New Hampshire, North Dakota, Tennessee, Virginia, Wisconsin and others. The law requires licensees to develop, implement and maintain a comprehensive written information security programme based on a risk assessment, designate a qualified individual responsible for the programme, conduct periodic risk assessments, encrypt nonpublic information in transit and at rest, implement multi-factor authentication for any individual accessing nonpublic information, conduct annual penetration testing and biannual vulnerability assessments, oversee third-party service providers, report cybersecurity events to the commissioner within 72 hours, and provide an annual certification of compliance. The engagement provides the penetration test, vulnerability assessment, third-party assessment template and the evidence pack the state insurance department examiner requests.

How do you cover broker portals and third-party agent ATO risk?+

Broker portals and agent extranets are the single most-targeted insurance attack surface in the public record. Credential stuffing using credentials leaked from unrelated breaches, MFA bypass through SMS interception or push-notification fatigue, OAuth misconfiguration on federated logins, session-fixation against legacy SAML stacks, and IDOR / BOLA breaks that let one broker enumerate another broker's book of business or a customer's policy data. The engagement runs authenticated testing against every broker and agent role, exercises the OWASP API Top 10 (2023) across the portal API, validates account-lockout and rate-limit thresholds against realistic credential-stuffing volume, tests the MFA enrolment and recovery flows for bypass, and runs targeted scenarios mirroring real third-party-agent account-takeover incidents — including post-ATO actions like quote manipulation, payout-bank-account change, and policy-level data exfiltration. Findings map to OWASP ASVS L2, OWASP API Top 10 (2023) and the relevant IRDAI / NAIC / IDD clauses.

Claims systems are core to our business. What does claims-fraud-focused testing look like?+

Claims platforms combine high-value workflow logic with PII, banking instruments, medical records (for health and motor injury claims) and third-party-agent access — making them the highest-impact target in any insurer's environment. The engagement exercises the OWASP ASVS L2 business-logic chapter (V11) and applies adversary-style testing against the claims lifecycle: First Notice of Loss (FNOL) intake manipulation, claim-status enumeration across customer accounts, claim-amount and reserve manipulation, payout-bank-account change without re-authentication, document-upload bypasses (PDF / image polyglots, MIME confusion, antivirus evasion), assessor and surveyor app abuse, and downstream impact on the core policy administration system (PAS) and the reinsurance ceding ledger. Where the insurer runs Guidewire ClaimCenter, Duck Creek Claims, Insurity, Sapiens, Majesco or a bespoke claims platform, we use the integration map to test the trust boundaries between modules — claims, billing, policy, reinsurance — because authorisation breaks at the integration layer drive the highest-impact fraud findings.

Reinsurers, brokers and MGAs each have a different stack. How does the engagement adapt?+

Reinsurers run a treaty and facultative book on systems like SICS, Tia, Sapiens ReinsuranceMaster or a bespoke ledger, integrated with the cedent insurers' bordereaux feeds and the retrocession outwards programme — the engagement targets the bordereaux ingest, the treaty-allocation logic and the retro accounting, where authorisation breaks create cross-cedent data exposure or premium-flow manipulation. Brokers and MGAs run placement platforms (PPL, Whitespace, ePlace), management systems (Acturis, Applied Epic, Vertafore AMS360) and customer portals integrated with the insurer panels — the engagement targets the placement-platform integrations, the panel-quote APIs and the customer-facing broker portal, with explicit testing of cross-broker data isolation. Insurtech firms typically run a thin policy-administration layer over a cloud-native stack and integrate with credit-bureau, KYC, payment and external-data APIs — the engagement covers the cloud control plane against the CIS Benchmarks, the API surface, and the third-party-integration trust boundary. The same evidence pack — VAPT report, OWASP / ASVS / API Top 10 mapping appendix, regulator-clause mapping appendix, retest report, Letter of Attestation — covers every entity type.

Scope an insurance engagement

Send the entity type (insurer, reinsurer, broker, MGA, web aggregator, insurtech), the lines of business, the core systems in scope (Guidewire, Duck Creek, Insurity, Sapiens, Majesco, bespoke), and the next regulator milestone (IRDAI inspection, NAIC examination, IDD review, ISO 27001 audit, SOC 2 cycle). We respond with a fixed-fee proposal and a redacted reference report under NDA.

Request a scoping call →