Insurance · AI Act

Insurance & AI Act: governing pricing and underwriting

The AI Act classifies risk assessment and pricing in life and health insurance among high-risk uses. Insurers, as major users of actuarial AI, must qualify each of their use cases and manage biases. This guide clarifies qualification, high-risk obligations, the exclusion of fraud detection, and the overlap with GDPR.

DPO / CISO team — Data Comply One Updated on 15 June 2026

In brief

  • Regulation: AI Act.
  • Insurers are concerned as deployers and, if they develop their own models under their own brand, as providers.
  • Classify systems.
  • Mastering data and biases.
  • Document and assess.
  • Up to €35M or 7% of turnover for prohibited practices and €15M or 3% for high-risk non-compliance, in addition to GDPR risk relating to health data and profiling.

Regulatory deadlines

The key dates of this regulation.

August 2024

Entry into force

In force

February 2025

Ban on prohibited practices

In force

August 2025

General-purpose AI models (GPAI) & governance

In force

August 2026

High-risk system obligations (Annex III)

In force

August 2027

High-risk embedded in products (Annex I)

Upcoming

What does the AI Act cover?

The AI Act classifies, in its Annex III, risk assessment and pricing with respect to natural persons in life and health insurance as high-risk. High-risk systems carry obligations relating to risk management, data quality, transparency, human oversight, and robustness.

Fraud detection is expressly excluded from this category; internal uses fall under lighter regulatory regimes.

Is the 'Insurance' sector affected?

Insurers are involved as deployers and, where they develop their own models under their own brand, as providers. Life and health pricing for natural persons is the emblematic high-risk use case.

Non-life lines or conversational use cases most often fall under lighter regimes, but remain subject to GDPR.

Detailed obligations

Classify systems

Mapping AI uses and isolating high risk (life/health pricing).

Control data and biases

Ensuring data quality and representativeness and controlling for bias, a central challenge in avoiding discrimination.

Document and assess

Build the technical documentation and carry out the conformity assessment.

Ensuring human oversight

Enable effective human oversight of pricing and underwriting decisions.

Inform policyholders

Ensure transparency on AI usage, in conjunction with the GDPR.

Sanctions & risks

Up to €35M or 7% of turnover for prohibited practices and €15M or 3% for high-risk non-compliance, in addition to GDPR risk relating to health data and profiling.

A biased pricing model exposes organisations to penalties and a discrimination risk with serious consequences.

Application timeline

  • 1Entry into force. 1 August 2024.
  • 2High risk. Main obligations from 2 August 2026 for life/health insurance pricing.

Common mistakes in the sector

  • 1High risk not identified. Treating life/health pricing as an ordinary use case.
  • 2Uncontrolled biases. Ignoring biases, a source of discrimination and non-compliance.
  • 3Cumulative GDPR forgotten. Failing to align the AI Act and GDPR on health data and profiling.
  • 4Superficial oversight. Displaying oversight with no real means of influencing the decision.

Practical case

A health insurer deploys a pricing model based on underwriting data. Classified as high-risk, it requires documentation, bias control, and human oversight. The insurer aligns these requirements with the GDPR exception for health data and the obligation to inform policyholders about profiling, addressing both regulations together.

Compliance roadmap

  1. 1

    Inventory. Inventory AI use cases (pricing, underwriting, fraud, claims, customer relations).

  2. 2

    Qualify. Isolating high-risk systems (life/health pricing).

  3. 3

    Strengthen reliability. Addressing data quality and biases.

  4. 4

    Document. Producing technical documentation and conformity assessment.

  5. 5

    Frame. Implementing oversight and information measures, coordinated with GDPR.

Frequently asked questions

In life and health insurance, with regard to natural persons, yes. Fraud detection is excluded from this category.

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