FIJISHI EPL

Fijishi Jurisdiction Index 2026 · Entry UK · Published 12 October 2026

At a glance

Jurisdiction tier	Tier C - Specified, not yet enforced. AI is specified as for Tier A, but no mechanism to check firms against it is stated.
Case examined	Aviva - a generative-AI tool that summarises GP reports for underwriters
Band for this case	Elevated
Rules reach	Insurers: directly · Reinsurers: not stated · Intermediaries: directly
Last verified	[actual date of the launch-window check]

1. The rules in United Kingdom

The Financial Conduct Authority says it is not going to introduce new regulations for AI and relies on existing frameworks. Its AI Update describes the Senior Managers and Certification Regime as relevant to the safe and responsible use of AI; under that regime each Senior Manager has a written Statement of Responsibilities.

The Prudential Regulation Authority's 2026 letter to insurers names AI as a source of opportunity and risk but states no AI-specific supervisory action.

Who these rules reach

• Insurers: directly. The FCA states: "Insurers were brought fully into the regime in December 2018".
• Reinsurers: not stated.
• Intermediaries: directly, where an FCA solo-regulated firm. The FCA states that the regime was "extended to cover all solo-regulated firms".

2. The case examined: Aviva - Elevated

This band describes how clearly the rules meet the AI use that Aviva has itself published. It is not a finding that Aviva has breached any rule.

Why Aviva: Aviva's own releases of 18 November 2025 and 18 March 2026 describe the tool's rollout and its effect on underwriters' review time.

The question

In November 2025 Aviva announced a rollout to its underwriting teams, from 28 November 2025, of a generative-AI tool that reduces lengthy GP reports - sometimes over 90 pages - to concise summaries, "filtering out irrelevant details and highlighting key information", with Aviva underwriters reviewing the summaries and making the final decision. By 18 March 2026, when Aviva extended the tool to individual critical illness applications, it reported that the tool had cut the time underwriters spend reviewing each case by around half. The FCA's AI Update (first published 22 April 2024) describes the Senior Managers and Certification Regime as "relevant to the safe and responsible use of AI", and notes that every Senior Manager has a Statement of Responsibilities setting out what they are responsible for. Whose Statement of Responsibilities at Aviva covers this tool - including the logic that decides which details of a GP report are left out of the summary an underwriter sees?

In brief

Aviva reports that its generative-AI tool summarises customers' GP reports for its underwriters, choosing what the underwriter reads, while the underwriter decides the case. The FCA points to the Senior Managers regime, under which each senior manager's responsibilities are written down, as the place where AI accountability sits. Aviva has not publicly said which senior manager is responsible for this tool.

Why this band: The question points to one firm and one named accountability instrument, but the binding regime it rests on does not name AI.

3. The same question for other firms in United Kingdom

Any firm under the Senior Managers regime that uses AI to shape what its underwriters see faces the same point: whose Statement of Responsibilities covers that tool. This entry gives no band to any firm other than Aviva.

4. What this entry does not establish

• Aviva's releases do not name the legal entity that uses the tool; it is identified from Aviva's product documents as Aviva Life & Pensions UK Limited.
• The FCA Handbook provisions on the Senior Managers regime were not read; the FCA's own summary is used.
• The FCA's review of AI in insurance (planned for early 2026) and its output were not read.

5. Dates ahead

• Later in 2026: the FCA's good and poor practice report on AI.
• Q1 2027: the FCA's AI Live Testing evaluation report.

See the Regulatory Deadline Calendar: Upcoming.

Sources

1. Aviva plc, "Aviva to launch groundbreaking AI Underwriting Tool", 18 November 2025 (printed). Company's own. aviva.com
2. Aviva plc, "Aviva extends industry-first AI underwriting tool to Critical Illness cover", 18 March 2026 (printed). Company's own. aviva.com
3. Aviva, Policy Summary of Critical Illness+, AL51001 04/2025 (printed). Company's own. static.aviva.io PDF
4. FCA, Financial Services Register entry for Aviva Life & Pensions UK Limited, printed Mon Sep 28 2026. Regulator. register.fca.org.uk
5. FCA, AI Update, first published 22 April 2024; last updated 3 December 2025 (printed). Regulator. fca.org.uk PDF
6. FCA, Senior Managers & Certification Regime page, last updated 24/04/2026 (printed). Regulator. fca.org.uk
7. PRA, Insurance Supervision: 2026 priorities, 15 January 2026 (printed). Regulator. bankofengland.co.uk PDF
8. FCA, Regulatory Priorities: Insurance, February 2026 (printed). Regulator. fca.org.uk PDF
9. FCA, "AI in financial services: shaping our approach through industry engagement", 8 June 2026 (printed). Regulator. fca.org.uk
10. FCA, press release, "FCA announces second cohort for AI Live Testing", first published 21/04/2026 (printed). Regulator. fca.org.uk

Related entries

None share a law or regulator with this entry.

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