The Actuarial Association of Europe has argued that actuaries bring a “distinctive contribution” to the governance of artificial intelligence (AI).

The comments were made in response to the European Insurance and Occupational Pensions Authority’s (EIOPA) Opinion on AI Governance and Risk Management, published in August.

The AAE was supportive of the authority’s principles-based and proportionate approach, which “provides clarity on how existing sectoral rules apply to AI systems”.

In particular, it welcomed the clarification of roles and responsibilities, including the accountability of the Administrative, Management or Supervisory Body (AMSB) and the explicit reference to the actuarial function’s role in overseeing AI systems within its remit.

This includes the coordination of technical provisions and providing an opinion on the overall underwriting policy.

“Overall, actuaries bring a distinctive contribution to AI governance. As members of professional bodies, they are required to meet rigorous standards in education, continuous professional development, codes of conduct, and practice standards, underpinned by disciplinary oversight,” the AAE stated.

The association added that actuaries’ “long-standing expertise” in risk management and their “systemic perspective on complex interactions” make them well positioned to support insurers, supervisors and policymakers in managing the opportunities and risks that AI presents.

It is a view shared earlier this year by the AAE, when it responded to the European Commission’s consultation on the classification of AI systems as high risk.

Furthermore, the AAE said EIOPA’s opinion helps to reduce uncertainty and to promote supervisory convergence across Europe.

“In line with our response to the consultation, we emphasise the importance of clarity on the boundary between traditional actuarial models, such as generalised linear models (GLMs), and AI systems.

This distinction, it said, is important to avoid unnecessary compliance burdens and to ensure consistent interpretation across the market.

“We also believe that proportionality should be applied not only with regard to the size, scale and complexity of undertakings, but also with regard to the potential impact of an AI system on customers,” it said.

It highlighted EIOPA’s six governance pillars: fairness and ethics, data governance, documentation and recordkeeping, transparency and explainability, human oversight, and accuracy, robustness and cybersecurity, as aligning well with existing frameworks in insurance.

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