TLDR: The Central Bank of Ireland has issued a strong warning to insurance companies, stating it will investigate whether firms possess adequate safeguards against the unethical deployment of new artificial intelligence technologies. The regulator emphasizes the critical need for robust governance and risk management frameworks to ensure the responsible and ethical use of AI, which is increasingly being adopted across the sector for various functions.
The Central Bank of Ireland (CBI) announced on October 1, 2025, its intention to scrutinize the insurance sector’s preparedness regarding the ethical and responsible use of artificial intelligence (AI). The regulator will investigate whether insurers have sufficient guardrails in place to prevent the unethical application of emerging AI technologies. This move comes as the insurance industry increasingly leverages AI, from established machine learning for data analysis and pricing to newer generative AI for underwriting and claims services.
Seána Cunningham, director of insurance at the Central Bank of Ireland, highlighted the importance of this oversight during a speech at the European Insurance Forum. “The management of new data and technologies… will require firms to consider carefully their ethical and responsible use, including the governance and controls required to oversee these technologies effectively,” Cunningham stated. She further added, “And we, as regulators, will be focused on developing a deeper understanding of use of artificial intelligence systems in the insurance sector and assessing whether firms have the necessary governance and risk management measures in place to harness innovation responsibly and well.”
The CBI acknowledges AI’s potential to enhance consumer experience but insists that stringent governance standards must accompany its adoption. The issue of bias in automated insurance pricing has previously drawn public attention, notably in 2018 when reports emerged in the UK about policyholders with certain names being charged higher premiums.
In line with its proactive stance, the Irish government has officially designated the Central Bank as a market surveillance authority under the EU AI Act (S.I. No. 366/2025 European Union (Artificial Intelligence) (Designation) Regulations 2025). This designation makes the CBI responsible for implementing, supervising, and enforcing the AI Act within its remit.
The Central Bank has already initiated a data-gathering exercise, including a survey distributed to selected firms in May 2025, to gain a comprehensive understanding of current and anticipated AI usage, AI strategies, and associated governance and risk management practices within the (re)insurance sector. This survey specifically incorporates an EIOPA-led (European Insurance and Occupational Pensions Authority) survey focusing on generative AI.
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Furthermore, the EIOPA published its Opinion on AI Governance and Risk Management in August 2025, which is addressed to EU member state competent authorities like the CBI. This opinion emphasizes key themes such as risk management, fairness and ethics, data governance, transparency, explainability, human oversight, accuracy, robustness, and cybersecurity, aligning with the CBI’s concerns.
