Solvency II and AI use cases

Annex III point 5(c): AI intended for risk assessment and pricing in relation to natural persons in life and health insurance. Article 6(3) exempts some purely preparatory tasks, but never a system that profiles natural persons. Extracting an applicant's health conditions and mapping them to the underwriting manual evaluates their health, which is profiling, so treat the system as high risk. Under the timeline as amended, the obligations for Annex III high risk systems apply from 2 December 2027, and Article 27 requires deployers of point 5(c) systems to assess the impact on fundamental rights before first use.

Pricing and risk assessment of natural persons for life and health insurance is high risk under Annex III point 5(c). Pricing for property and casualty products, and actuarial analysis that does not price individuals, are not listed, although supervisors still expect sound model governance.

For commercial property and casualty lines the copilot is not listed in Annex III. Used for risk assessment of natural persons in life or health insurance it falls under Annex III point 5(c) and is high risk, with risk management, data governance, logging and human oversight duties, and deployers must carry out a fundamental rights impact assessment under Article 27.

Claims handling as such is not listed in Annex III. The same system becomes high risk when it is also used for risk assessment and pricing of natural persons in life and health insurance (point 5(c)), or when it is used by or on behalf of a public authority to grant, reduce, revoke or reclaim essential public assistance benefits and services, including healthcare services (point 5(a)). Otherwise the tier is minimal, so the design and the operator decide. Decisions on claims based solely on automated processing are also subject to Article 22 of the GDPR and the UK GDPR.

Annex III point 5(a) makes AI high risk when it is used by or on behalf of public authorities to evaluate eligibility for essential public assistance benefits and services, including healthcare services, or to grant, reduce or revoke them, which can cover statutory health schemes run by or for public bodies. Point 5(c) covers risk assessment and pricing in life and health insurance, not claim review. A copilot for a private insurer's claim review, where people decide, is usually outside Annex III; for public schemes, Article 6(3) may exempt a system that only performs a preparatory task, unless it profiles natural persons. GDPR rules on health data (Article 9) and on solely automated decisions (Article 22) apply in every case.

Not an Article 5 practice and not listed in Annex III: the system prepares filings for authorities and makes no decision on the credit, insurance, employment or access to services of a natural person. It is an internal tool whose users know they are working with AI, and drafted text that ends up in public disclosures passes human review under a named person's editorial responsibility, which takes it outside the Article 50(4) deployer disclosure duty. The system still drafts variance commentary and plain language explanations of validation failures from underlying data, rather than lightly editing existing text, so the assistive function for standard editing exception does not fit. The bank that builds or operates the system is then the provider and carries the Article 50(2) duty to mark that generated text in a machine readable way as artificially generated, which has applied since 2 August 2026. The AI literacy duty of Article 4 also applies.

A validation copilot supports internal governance and is not itself an Annex III use, and its drafts are internal, so Article 50 transparency duties do not normally apply. It often helps validate models that are high risk under Annex III (point 5(b), creditworthiness and credit scoring of natural persons; point 5(c), life and health insurance pricing), and the testing and documentation it supports feed the provider obligations of Articles 9, 11 and 15.

Intake and triage for commercial insurance is not listed in Annex III, which covers risk assessment and pricing of natural persons in life and health insurance. It moves up to high risk only if the same pipeline is used to assess or price life or health cover for individuals.