Life and health risk assessment is high-risk and owes a mandatory FRIA.
AI used to assess risk for life and health insurance is Annex III point 5(c) and requires a fundamental rights impact assessment before first use. Pricing models that touch health or mortality carry the highest documentation burden in the Act.
- Annex
- Annex III · 5(c) — risk assessment and pricing for life and health insurance
- Provisions
- Art. 27(1)(b) · Annex III 5(c) · Art. 26 · Art. 10
- Pack
- €199/month add-on · 4 duties · 1 notice templates
Why this sector is different
Insurance combines a mandatory FRIA with special-category data and a vulnerable population. The actuarial justification you already hold answers the performance questions; the gap is fundamental-rights reasoning and the explanation a declined applicant receives.
Complete the Article 27 FRIA before first use of the pricing model
Mandatory for Annex III 5(c). Health-related pricing will usually also need a GDPR Art. 9 condition.
Art. 27 · due within 21 days of activation
Document the Art. 9 GDPR condition for health-related inputs
Health data in a pricing model needs an explicit condition, not just a DPA.
Art. 10 · GDPR Art. 9 · due within 30 days of activation
Test for proxies of protected characteristics
Postcode, occupation and lifestyle variables can act as proxies. Record the test and the outcome — an untested model is not a benign one.
Art. 10(2)(f) · Art. 15 · due within 60 days of activation
Give a declined applicant the main factors and a review route
The explanation must be meaningful to the person, not the model's feature importance table.
Art. 86 · due within 45 days of activation
The notices you owe
Unlocked with the pack, rendered with your own facts, blanks kept where you must decide.
Applicants and policyholders
Underwriting notice — AI-assisted risk assessment
{company} uses an automated system to help assess risk and price this product. The system considers {dimensions}. A person reviews the outcome before a decision is communicated. You may ask which main factors influenced …
What your buyers will ask
The questions that stall a deal or trigger an audit. Each one is a control in the matrix.
- ?Show the FRIA for life and health pricing.
- ?How do you test for proxies of protected characteristics?
- ?What does a declined applicant receive?
Straight answers
Which insurance AI requires a FRIA?
Systems used to assess risk and price for life and health insurance — Annex III point 5(c). Property, motor and commercial lines generally fall outside the high-risk list, though the transparency and data-protection duties still apply.
Are we a provider or a deployer?
Usually a deployer of a vendor's model, which means Article 26 duties and the FRIA. But if you build the model in-house and place it on the market, or substantially modify a vendor model, you become a provider under Article 25(1) with the full Annex IV documentation burden.
Know where you stand before the questions arrive.
Four minutes, no card. You get your exposure score and the exact articles that apply to a insurance organisation.