LO
ConstraintCognitive automation2025-08-06
EIOPA's Opinion made the actuarial function responsible for the controls on AI systems within its remit, and recorded that AI for life and health insurance pricing is high-risk under the AI Act
Actuaryoccupation page →
Event date / reported
2025-08-06
Evidence stage
ConstraintFailure, rollback, regulation or cost is suppressing adoption. Can lower an assessment or widen its uncertainty.
Tasks this bears on
Building the pricing model
Deciding which factors set the price of a policy, fitting the model, and defending why each factor belongs there.
Being augmented✓ Evidence-backed
Setting the reserves
Estimating what the insurer will have to pay on the policies it has already written, and choosing the assumptions that number rests on.
Being augmented✓ Evidence-backed
Testing a model for unfair discrimination
Running the checks that show whether a model treats protected groups differently, before it goes live and again afterwards, and documenting the answer.
New task✓ Evidence-backed
Signing off on the numbers
Giving the formal opinion that the reserves are adequate or the underwriting policy is sound — the statement a regulator reads with a person's name on it.
Still human-led✓ Evidence-backed
Where this applies
The European insurance supervisor's own Opinion of 6 August 2025, addressed to national competent authorities rather than directly to firms. Read in the full PDF. Paragraph 2.4: the AI Act identifies as high-risk the use of AI systems for risk assessment and pricing in relation to natural persons in life and health insurance. In its description of roles, it states that the actuarial function is responsible for the controls on AI systems that fall under its responsibilities, giving as examples the coordination of the technical provisions calculation and the opinion on the overall underwriting policy. Its annex on fairness metrics warns that some group fairness metrics could contradict actuarial fairness, where customers bearing the same risk are charged the same price. It establishes where responsibility sits in EU insurers; it does not measure how much of actuarial work software does, and it counts no one.
What this means
The EU insurance supervisor names the actuarial function as responsible for controls on AI within its remit, including in technical provisions and the underwriting-policy opinion, and records that AI pricing in life and health insurance is high-risk.
What it does not yet show
It places responsibility; it does not show how much of the calculation software now does, how many actuaries insurers employ, or how national authorities will supervise it.
What you can check
Read your insurer's AI governance policy and check whether it gives the actuarial function the controls this opinion describes, and who signs for them.
Does it change the assessment?
No. The impact index is never moved by a single event. Of the 4 linked judgements above, 2 moved from inference to evidence with this record; the other 2 already rested on earlier evidence.
Source
European Insurance and Occupational Pensions Authority — Opinion on Artificial Intelligence governance and risk management, EIOPA-BoS-25-360 · verified 2026-09-23 · Claude (VOLO agent) — source text fetched and cross-checked · interpreted 2026-09-23 · Claude (VOLO agent) — source text fetched and cross-checked
Primary source — published by the party that did this, or the authority of record. No co-signature needed.