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 | Sukoon Insurance - AI measurement of applicants' health metrics in life underwriting |
| Band for this case | Elevated |
| Rules reach | Insurers: directly · Reinsurers: not stated · Intermediaries: not stated |
| Last verified | [actual date of the launch-window check] |
The Central Bank of the UAE issued a Guidance Note on the consumer protection and responsible use of AI and machine learning by licensed financial institutions in February 2026. It covers insurance providers and says customers should be told about AI use in high-impact decisions and be able to ask for human review.
The Guidance Note is written as principles and states no supervisory follow-up. The federal data protection law's right to object to automated decisions awaits executive regulations and excludes health data covered by its own legislation.
Who these rules reach
- Insurers: directly. The Guidance Note covers "licensed financial institutions, including insurance providers (LFIs)".
- Reinsurers: not stated.
- Intermediaries: not stated.
This band describes how clearly the rules meet the AI use that Sukoon Insurance has itself published. It is not a finding that Sukoon Insurance has breached any rule.
Why Sukoon Insurance: Sukoon's own release of 4 February 2025 and its Integrated Report 2025 describe AI that measures applicants' health metrics from a video.
The question
In briefSukoon Insurance announced on 4 February 2025 that it had launched an AI-powered face-scanning feature for life-insurance applications which "analyzes a short video of the applicant's face to meticulously measure key health metrics like heart rate, blood pressure, and respiration rate", removing the need for traditional medical exams. Its Integrated Report 2025 lists an AI-enabled life insurance application among its 2025 milestones. The Central Bank of the UAE's Guidance Note on the consumer protection and responsible use of AI and machine learning by licensed financial institutions, issued in February 2026 and covering insurance providers, says that institutions should be transparent with customers about AI use, particularly for high-impact decisions, and that consumers should be able to request human review or explanation of AI-generated decisions. Where an applicant's life cover is priced or declined on health metrics measured this way, does Sukoon regard that as an AI-generated decision under the Guidance Note, which the applicant is told about and can ask a person to review, or as an underwriter's decision that draws on AI-measured evidence?
Why this band: The question points to one firm and one process, but the Guidance Note is not binding.Sukoon uses AI to measure life-insurance applicants' vital signs from a video of their face, in place of a medical exam. The Central Bank of the UAE's AI guidance asks insurers to be open with customers about AI in high-impact decisions and to let them have AI-generated decisions reviewed by a person. Sukoon has not said in any publication we found whether underwriting decisions based on these AI measurements are treated that way.
3. The same question for other firms in United Arab Emirates (mainland)
Any insurer in the UAE mainland that uses AI-measured evidence in underwriting faces the same point: whether it treats the resulting decision as an AI-generated decision the applicant is told about and can have reviewed by a person. This entry gives no band to any firm other than Sukoon Insurance.
4. What this entry does not establish
- How the metrics are used in the underwriting decision, and whether an underwriter reviews every case. This entry says nothing either way.
- Whether the face-scanning feature has been in use since January 2026.
- The exact issue day of the Guidance Note: the Rulebook prints 11/2/2026, and the announcement was reported on 25 February 2026.
- The federal data protection law was read through a processed copy, and the status of its executive regulations rests on two secondary sources.
- No date set: any Central Bank follow-up on the Guidance Note; the data protection law's executive regulations.
Sources
- Sukoon Insurance, "Sukoon Insurance uses AI to speed up life insurance applications", February 4, 2025 (printed). Company's own. sukoon.com
- Sukoon Insurance P.J.S.C., Integrated Report 2025 (Board report signed 28 January 2026, printed). Company's own. sukoon.com PDF
- Central Bank of the UAE, Guidance Note on the Consumer Protection and Responsible Adoption and Use of AI and ML by Licensed Financial Institutions, issued on 11/2/2026 (printed on the Rulebook page). Regulator. rulebook.centralbank.ae
- Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. Statute. uaelegislation.gov.ae
None share a law or regulator with this entry.
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Commercial relationship with any party named here: None · Right of reply: indexreport.protocol@fijishi.com; with the sender's agreement, replies are published in full below the entry, dated · Cite as: Fijishi Jurisdiction Index 2026, Entry AE · Corrections: none.