The agency deck has a slide called “Partner growth plan”. It promises to recruit affiliates, write their posts, run the tracking links and pay everyone per approved policy. It is a good slide. What it leaves out is the question your compliance head will ask first: is each of those affiliates allowed to be paid for selling insurance in India? That question marks the line between what a marketing agency can do for your partner programme and what it cannot.
A partner marketing agency should build the kit while your team owns the partners
A partner marketing agency is most useful to a regulated brand when it builds the kit partners sell with and leaves the partners themselves to you. That is our position, and the rest of this piece argues it. It applies to fintechs, insurers, lenders, asset management companies (AMCs) and B2B software firms that sell into them.
A few terms first, because programmes mix them up. A referral partner sends you customers and is paid for the introduction. An affiliate publishes content or links and is paid per sale or lead, often on a cost per acquisition (CPA) basis. A direct selling agent (DSA) sells or promotes a lender’s products under a contract. A distributor or intermediary is a registered entity, such as an AMFI-registered mutual fund distributor or an IRDAI-registered insurance intermediary, that is licensed to sell and be paid for it.
The four have different legal footing. In consumer retail or software, the difference barely matters, and an agency can treat them as one channel. In financial services, the difference decides who you may pay, what they may say and who is answerable when a customer complains. That is why the split between system and partners matters more here than anywhere else.
The kit is everything a partner touches: the landing page template, the approved ad and post formats, the disclosure layouts, the training module, the FAQ the partner can quote and the dashboard that shows which partners bring customers who stay. Your team keeps the partner list, the contract, the commission terms, the eligibility checks and the final approval. Our partner and affiliate marketing hub sets out how we split the work in practice.
What do partner programmes usually hand to an agency today?
Most partner programmes outside regulated finance hand almost everything to one outside firm. That might be a performance agency, an affiliate network or a partner management agency. The model is popular for sound reasons, and it is fair to describe it on its own terms before arguing with it.
A typical full hand-off covers recruiting partners from the agency’s own network, running the tracking platform and the partner portal, writing co-marketing content for partners to post, managing the payout calendar and reporting cost per acquisition each month. The brand approves a budget and a target CPA, then reviews a dashboard.
This works well for a direct-to-consumer apparel brand or a project management tool. There is one invoice and one contact to call. The agency already knows hundreds of content creators and coupon sites. The brand’s team stays small, and the cost scales with sales.
The full hand-off also suits how partner budgets are often approved. A chief revenue officer can sign a CPA target in a single meeting. Nobody has to build an approvals workflow or a training module, because the agency promises to handle content and conduct. For a product with no regulator behind it, that promise is usually good enough. The trouble starts when the product is a loan, a policy or a fund.
SIGNALNewsletter by Yamm Labs
The next piece, straight to your inbox.
New writing on BFSI brands, B2B and influencer marketing, and AI search.
One click to unsubscribe. Privacy policy
Why does the full hand-off break for banks, insurers, lenders and AMCs?
The full hand-off breaks because Indian financial regulators place the duty for what partners do on the regulated brand, and no agency contract moves it. Each regulator words this differently, but the effect is the same across lending, insurance and mutual funds.
Insurance. India’s insurance law bars anyone from paying commission or any other reward for soliciting or procuring insurance business to a person who is not an insurance agent or a registered insurance intermediary. A content creator with a tracking link who is neither cannot be paid per policy, however good the content is. Under IRDAI’s 2024 regulations on protecting policyholders’ interests, an advertisement issued by a distribution channel needs the insurer’s written approval before it is issued, and every insurer advertisement must show the insurer’s registered name with its trade name or logo prominently. See IRDAI’s 2024 policyholder protection regulations.
Mutual funds. AMFI’s master circular for mutual fund distributors says distributors must use the marketing material the AMC provides and must not design their own material for any scheme without the AMC’s approval. It requires distributors to disclose the commissions they receive across the competing schemes they recommend from, and it bars them from passing commission back to investors as a rebate. The AMFI master circular for distributors is the document your AMC’s compliance team will check partner content against.
Securities. SEBI’s circular of October 2024 says entities regulated by SEBI, and their agents, may not associate with a person who gives securities advice or makes claims of return or performance unless that person is registered with or permitted by SEBI. Investor education without advice or return claims is excluded. A broker or AMC that pays an unregistered finfluencer to talk up returns is the one in breach.
Banks and lenders. RBI’s amendment directions for commercial banks, issued on 15 June 2026 and effective from 1 January 2027, require a bank to keep an up-to-date list of its DSAs and direct marketing agents (DMAs) on its website. Before assigning sales work, the bank must get an undertaking from each DSA that it and its sub-agents will follow the bank’s code of conduct. The bank must also make sure its policies do not create incentives for mis-selling, and where mis-selling is established it refunds the customer in full. The text is on RBI’s notification page.
Digital lending. RBI’s digital lending directions say an outsourcing agreement with a lending service provider (LSP) does not dilute the lender’s obligations. The lender remains fully responsible and liable for the LSP’s acts and omissions, and fees owed to the LSP must be paid by the lender directly, never collected from borrowers by the LSP.
Advertising standards. ASCI’s guidelines for influencer advertising list “Affiliate” among the labels that can disclose a material connection, and they expect the label upfront and prominent. A partner post that hides the label in a cluster of hashtags does not meet that standard.
Read together, these rules make the brand answerable for who its partners are, what they say and how they are paid. An agency can help you meet each duty. It cannot hold any of them for you.
Hire an agency to build what your partners sell with, and never to answer for what they say.
Which compliance decisions does a partner programme have to make before launch?
A regulated partner programme has to settle four decisions before the first partner goes live, and each one changes what the agency builds. Leaving them to the agency means they get made by default, usually in favour of speed.
- Who approves partner creatives. Decide whether partners may only use assets from your approved library, or may also submit their own for review. For an insurer, any distribution-channel advertisement needs the insurer’s written approval before issue, so the cleaner design is a library of pre-approved formats where the partner can change only fields you name, such as their name and a referral code. For an AMC, distributors are expected to use AMC-supplied material in the first place.
- What an affiliate may say about the product. Write a short list of permitted claims and a list of banned ones. For a credit card, the permitted list might cover the joining fee and reward rate exactly as they appear on your product page. The banned list covers “guaranteed approval”, any return figure for a fund and any comparison with a named competitor.
- How commissions are disclosed. Decide where the partner tells the customer that they are paid. In a creator video, that means the “Affiliate” or “Ad” label in the opening frame, in line with ASCI’s guidelines. On a mutual fund distributor’s page, it means the commission disclosure across competing schemes that AMFI’s rules expect.
- Who is eligible to be paid at all. Map each partner type to the registration it needs. Insurance commission goes only to agents and registered intermediaries. Mutual fund commission goes to AMFI-registered distributors quoting a valid ARN. A bank’s DSA signs the code of conduct undertaking first. Everyone else gets an unpaid referral route or a flat, non-product fee your legal team has cleared.
An agency can turn each decision into a working asset. The template with a locked disclaimer band, the claims sheet in the training module, the label rule in the creator brief and the sign-up form that asks for an ARN are all agency work. The decisions behind them are yours. Our guide for AMCs, what to ask a mutual fund marketing agency, covers the distributor side in more detail.
This is general guidance, not legal advice. Your compliance team decides how each rule applies to your products.
Current practice against what we propose
The table compares the usual full hand-off with the split we recommend for regulated brands. The left column is a fair summary of how many consumer partner programmes run. The right column is what changes when the product is regulated.
| Area | Common practice | Proposed for a regulated brand |
|---|---|---|
| Partner recruitment | Agency recruits from its own network of creators and sites | Agency writes recruitment pages aimed at registered intermediaries; your team checks registration before onboarding |
| Creative | Partners adapt agency content freely | Pre-approved library with locked disclosure zones; partners edit named fields only |
| Claims | Agency briefs partners on key benefits | A written permitted and banned claims list, approved by compliance, built into training |
| Disclosure | Left to each partner’s habit | Label position fixed in the template, such as the first line of a caption or the opening frame of a video |
| Commission | Agency manages payouts per CPA target | Your team sets terms by partner type; agency reports, does not pay |
| Approval | Agency approves partner posts | Your compliance team approves templates once; agency samples live posts and flags drift |
| Reporting | Cost per lead or click | Cost per approved customer, plus complaints and cancellations by partner |
The right column costs more effort at the start. It saves the repeated review of every partner post, which is where most regulated programmes lose weeks.
What can a partner marketing agency do that your own team usually cannot?
A partner marketing agency can build and maintain the kit faster than an in-house team, because it designs for many partner types at once and has made the same templates before. These are the jobs worth paying for.
- A creative system partners cannot break. Templates where the brand lockup, the registered name and the disclaimer sit in fixed zones, and the partner edits only a headline from an approved list and their own contact line. For a lender, the template links to your own page where the Key Facts Statement is shown, so no partner ever quotes a rate.
- Partner landing page templates. One page per partner type, each carrying the right tagline and disclosure. A mutual fund distributor’s page shows “AMFI-registered Mutual Fund Distributor” with their name and ARN. An insurance intermediary’s page shows the insurer’s registered name.
- Onboarding and training content. Short modules that teach the permitted claims list, show the banned phrases and end with a quiz, so you can keep a record of who completed training. RBI’s bank amendment expects sub-agents to hold any qualification the relevant regulator prescribes, and a training record is the evidence.
- Recruitment content for the right partners. Pages and outreach aimed at registered distributors, intermediaries and B2B software partners, with eligibility stated up front so unregistered applicants filter themselves out.
- Measurement tied to approved customers. A dashboard that reports each partner’s approved customers, early cancellations and complaints, so a high-volume partner who sends poor-fit customers is visible within a month.
Our page on partner and affiliate marketing for fintech walks through how these pieces fit a lending or payments programme.
Try this: ask any agency you are considering to show you one partner template where the disclosure cannot be moved or deleted by the partner. If they cannot, they are offering content, and the system is still missing.
What should an agency never be asked to own?
An agency should never own the decisions that a regulator will later ask your brand to explain. Five sit in that group.
- Checking whether each partner holds the registration needed to be paid, such as an ARN for mutual funds or an intermediary registration for insurance.
- Setting commission terms, because AMFI bars rebates, insurance law limits who may receive commission and RBI expects banks to avoid incentives for mis-selling.
- Final approval of creatives and claims, which belongs with your compliance reviewer.
- The partner contract, including the code of conduct undertaking a bank collects from its DSAs.
- The complaints and mis-selling record, which feeds refunds and regulatory reporting.
An agency can support every one of these with forms, trackers and reports. The test is simple. If the regulator writes to you about it, your name is on the reply, so your team holds the decision.
There is a commercial reason too. When an agency both recruits partners and is paid on volume, it has a quiet incentive to wave through the partner who sells hard. Keeping eligibility and payouts in-house removes that conflict before it starts.
The strongest counter-argument: one vendor running everything is faster
The strongest case against our view is speed. A single partner marketing agency that recruits, tracks, pays and reports can launch a programme in weeks, and a split model asks your team for staff and decisions it may not have. That objection is right in several cases, and it deserves a full hearing.
It is right for B2B software partner programmes where the product is not itself regulated. A payments software company recruiting implementation partners does not need an ARN check. A full hand-off there is sensible, as long as the agency follows ASCI’s disclosure rules for any paid content.
It is also right that small fintech teams struggle to staff a partner function. A seed-stage lender may have one growth lead and a part-time compliance adviser. Asking that team to run eligibility checks, contracts and approvals feels like a tax on growth.
Our answer is that the speed is real, but the accountability does not move with it. RBI’s digital lending rules say an outsourcing agreement does not dilute the lender’s obligations. The same logic runs through IRDAI’s approval rule and AMFI’s material rule. A fast launch that pays an unregistered affiliate per policy is a fast route to a refund bill and a regulator’s letter.
The workable compromise is to let the agency run operations under your rules. The agency can process applications, chase documents and prepare payout files, while your team approves eligibility and releases payments. You keep most of the speed and none of the confusion about who decided.
What should a partnerships lead do on Monday?
A partnerships lead can start the split model in one week with five steps, before any partner marketing agency is briefed.
- List every partner type you pay or plan to pay, and next to each, the registration it needs. Mark any partner type with no registration as unpaid until legal clears a route.
- Ask compliance for the permitted and banned claims list for your top two products. One page each is enough to start.
- Pick one template, such as a creator post or a distributor landing page, and agree with compliance where the disclosure and registered name sit. That becomes the locked zone the agency builds around.
- Write the commission terms by partner type yourself, and keep the payout approval with finance.
- Brief agencies on the kit only, and ask each to show a locked template, a training module with a completion record and a dashboard that reports approved customers.
What to tell your compliance team, in one email: “We are splitting the partner programme. The agency builds templates with fixed disclosure zones, a claims sheet and training. We keep eligibility checks, commission terms and final approval. You approve each template once, and the agency samples live partner posts each month and flags anything off-template.”
What would change our view?
Our view rests on the current rules, so a change in those rules would change it. Three developments would move us.
The first is a partner marketing agency that itself holds the relevant registration. If the agency is a registered intermediary for the product, part of the accountability sits with it by law, and a fuller hand-off becomes defensible for that product.
The second is a regulator moving liability for paid content onto the publisher. SEBI and ASCI have both written rules for finfluencers in recent years. If future rules made the paid partner directly answerable for what it publishes, the brand’s review burden would shrink, though its eligibility checks would stay.
The third is evidence. If a regulated brand published data showing that a full agency hand-off produced no more complaints or cancellations per approved customer than an in-house model, we would take it seriously. As of October 2026 we have not seen such a comparison in public.
Until one of those happens, the split holds. The agency builds, your team decides, and every partner works from a template your compliance reviewer has already seen.
People also ask
What does a partner marketing agency do?
A partner marketing agency builds the assets and processes a partner programme runs on: recruitment pages, co-branded templates, training content and reporting. For a regulated brand, the useful agency also designs the disclosure layouts and claims lists into those assets. It should not decide who gets paid or give final approval.
Can an affiliate earn commission for selling insurance or mutual funds in India?
Only if the affiliate holds the right registration. Indian insurance law limits commission for soliciting insurance to agents and registered intermediaries, and mutual fund commission goes to AMFI-registered distributors. An unregistered creator can publish educational content or use an unpaid referral route your legal team has cleared.
Who should approve partner creatives in a regulated programme?
Your own compliance team, not the partner marketing agency. Insurers need to give written approval before a distribution-channel advertisement is issued, and AMFI expects distributors to use AMC-supplied material. The efficient design is a library of templates approved once, with the agency sampling live posts for drift.
Want to know how your partner kit reads to a compliance reviewer?
Get a free Fintech Brand Audit across 8 dimensions, plus 3 fixes. No pitch. Run the free Brand Audit →