"... The increase in insurance premiums must be based on factors that increase insurance risks.

The reduction in insurance premiums must ensure that in all cases the insurance premium after the reduction is not lower than the pure insurance premium and is based on one or more factors that reduce, disperse, share risks or reduce the cost of implementing motor vehicle insurance products, including the scale of the number of insured vehicles, the choice of deductible level, deductible level, compensation history, form of product distribution and other factors (if any), in case of reduction in insurance premiums due to sales directly, the reduced insurance premium does not exceed the insurance agent commission rate as prescribed in Article 51 of this Circular;". Mr. Q. asked, in the case of reducing insurance premiums due to direct sales, the reduced premium does not exceed the agent commission rate as prescribed in Article 51 of Circular 67/2023/TT-BTC, is it possible to reduce the net premium beyond the prescribed net premium? It can be understood that if selling directly, is it allowed to reduce the net premium by an additional part corresponding to the agent commission rate?

Regarding this issue, the Department of Insurance Management and Supervision, Ministry of Finance has the following comments:

According to Point d Clause 1 Article 25 Circular No. 67/2023/TT-BTC dated November 2, 2023 guiding:

"d) Implement specific registration of cases and bases for increasing and decreasing insurance premiums.

The increase in insurance premiums must be based on factors that increase the insured risks.

The reduction in insurance premiums must ensure that in all cases, the insurance premium after the reduction is not lower than the pure insurance premium and is based on one or more factors that reduce, disperse, share risks or reduce the cost of implementing motor vehicle insurance products, including the scale of the number of insured vehicles, the choice of deductible level, deductible level, compensation history, product distribution form and other factors (if any). In case of reducing insurance premiums due to direct sales, the reduced insurance premium level does not exceed the insurance agent commission rate according to regulations specified in Article 51 of this Circular;".

According to Point 3.1 Clause 3 Article 51 of Circular No. 67/2023/TT-BTC: "Maximum insurance agent commission rate for insurance contracts under non-life insurance: 7. Motor vehicle insurance (except civil liability insurance of motor vehicle owners): 10%".

We request that you base on the above legal provisions to study and implement in accordance with legal provisions.