EU AI Act Readiness Checklist for Insurance Platforms

This checklist helps insurers and MGAs assess whether their websites and digital services are prepared for EU AI Act compliance.

It focuses on practical platform and system requirements, not legal theory.

1. AI Use Case Identification

☐ Have all AI use cases been clearly identified?
☐ Is AI used in underwriting, pricing, claims, or fraud detection?
☐ Does AI influence customer eligibility or financial outcomes?
☐ Are third-party AI services documented?

2. High-Risk AI Classification

☐ Have AI systems been assessed for high-risk classification?
☐ Is there clarity on which systems fall under the EU AI Act?
☐ Are decision-support tools evaluated realistically?
☐ Is responsibility clearly defined (insurer, MGA, vendor)?

3. Transparency & Explainability

☐ Are users informed when AI is involved in decisions?
☐ Can decisions be explained in plain language?
☐ Are AI-generated outputs distinguishable from manual decisions?
☐ Is explanation accessible to both staff and customers?

4. Human Oversight & Control

☐ Can humans intervene or override AI decisions?
☐ Are approval flows built into underwriting and claims?
☐ Are escalation paths defined for edge cases?
☐ Is responsibility assigned to specific roles?

5. Auditability & Logging

☐ Are AI inputs and outputs logged?
☐ Are model versions tracked?
☐ Can decision paths be reconstructed?
☐ Are logs retained for regulatory and dispute purposes?

6. Bias & Risk Monitoring

☐ Is AI performance monitored after deployment?
☐ Are bias and fairness risks assessed?
☐ Are alerts in place for anomalous behaviour?
☐ Is there a defined incident response process?

7. Vendor & Third-Party Governance

☐ Are AI vendors contractually assessed for compliance?
☐ Is vendor documentation available and up to date?
☐ Can vendor AI decisions be audited?
☐ Are fallback options available?

8. Platform Architecture Readiness

☐ Is AI modular and not hard-coded?
☐ Can AI models be updated or replaced?
☐ Is governance built into the platform architecture?
☐ Is the system scalable across products and regions?

9. Documentation & Governance

☐ Is AI system documentation maintained?
☐ Are responsibilities clearly assigned?
☐ Is there an internal AI governance process?
☐ Is compliance reviewed regularly?

10. Future-Proofing for AI SaaS

☐ Is compliance built into new product design?
☐ Can AI features be safely expanded?
☐ Is the platform ready for AI-driven SaaS products?

How to Use This Checklist

If you answered “no” to several items, your platform may require architectural or workflow changes to support EU AI Act compliance.

For deeper context, read our full guide: EU AI Act & Insurance Platforms: What Insurers and MGAs Need to Build Now

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