Insurers use AI to price, underwrite, handle claims and detect fraud, with a direct impact on access to life and health coverage. The EU classifies life and health insurance pricing as high-risk, and supervisors such as EIOPA, Peru's SBS and New York's regulator already expect data governance, explainability and discrimination testing.
Relevant sector rules
EU: risk assessment and pricing for life and health insurance are high-risk from Dec 2, 2027 and require a FRIA; EIOPA's August 2025 Opinion expects data governance, record-keeping, fairness, explainability and human oversight built into risk management. Spain: GDPR and DGSFP supervision. Peru: the SBS model risk regulation covers insurers from Jan 1, 2026. US: the NAIC model bulletin on AI (adopted by many states), NYDFS Circular Letter No. 7 (2024) on AI in underwriting and pricing, and in Colorado SB 21-169 and its life insurance regulation; Colorado SB 26-189 treats insurance as a consequential decision from Jan 1, 2027. Ecuador, Colombia, Mexico, Chile, Argentina and Brazil: no AI-specific insurance rule; data protection laws apply.
Model risk with inventory and materiality, adverse-decision explanation letters, human review, a decision log, technical model documentation and the EU AI Act Art. 26 checklist for high-risk systems.