AI Act FAQ

AI in Insurance: Frequently Asked Questions

5 questions answered with specific EU AI Act article references. 98 days until the August 2, 2026 enforcement deadline.

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Is insurance AI high-risk?

Yes. AI systems for risk assessment and pricing in life and health insurance are high-risk under Annex III category 5(c).

What about property insurance AI?

Property and motor insurance AI is not explicitly listed in Annex III 5(c), which covers 'life and health insurance.' However, if the AI system denies access to essential services, it may still be high-risk.

What must insurers do?

Risk management system, technical documentation, non-discrimination testing (critical for insurance pricing), transparency to policyholders, human oversight for coverage denial decisions, and FRIA.

Does Solvency II interact?

Yes. AI risk models must comply with both AI Act conformity requirements and Solvency II model validation standards. Dual governance is required.

Can AI deny insurance coverage?

Only with human oversight and explainability. Automated denial of life/health insurance based solely on AI output likely violates both AI Act Article 14 and GDPR Article 22.

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