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White paperMichael Clark
Material to Whom?
Insurers who scope AI Act work to Annex III, whose only insurance-specific use is life and health risk assessment and pricing, leave most of their AI estate to EIOPA's Opinion of 6 August 2025 and the Solvency II, IDD and DORA duties it interprets. Our working hypothesis is that this sectoral regime covers more of a typical composite insurer's AI estate than Annex III. The recommended path is to find the systems the model inventory misses, record a reasoned fairness metric per product, carry out impact assessments where Annex III points 5(b) and 5(c) apply, and keep a decision record.
Key findings
- Annex III names one insurance-specific high-risk use: risk assessment and pricing in relation to natural persons in life and health insurance.
- EIOPA's Opinion sets out no new requirements, but it sets supervisory expectations for AI systems that are neither prohibited nor high-risk, grounded in Solvency II, the IDD and DORA.
- Our working hypothesis is that, for a typical composite insurer, the sectoral regime covers more of the AI estate than Annex III does, though the balance varies with business mix.
In the paper
- Three regimes, three questions
- What the Opinion is
- Three points easily misread
- Holding the data to test for bias
- Traditional actuarial models
- The obligation buyers miss
- Where the exposure sits
- Where to start
Michael Clark
Chief Executive Officer, Standard Intelligence
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