FIJISHI EPL

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

At a glance

Jurisdiction tier	Tier A - Specified and enforced. A binding instrument that applies to insurers' own use of AI, or an issued regulator document addressed to this insurance market, addresses AI - by name or by an unambiguous description such as "predictive models" or "automated decision system" - and sets out rules or expectations that apply to it; and the regulator has a live mechanism to check or sanction them.
Case examined	Pacífico Seguros - AI resolving and paying claims
Band for this case	Elevated
Rules reach	Insurers: directly · Reinsurers: directly · Intermediaries: directly
Last verified	[actual date of the launch-window check]

1. The rules in Peru

Peru's AI regulation, Supreme Decree DS 115-2025-PCM (9 September 2025), required finance-sector uses to implement its obligations by 10 September 2026. Its human-supervision duty applies to AI it classes as high-risk; that list names credit evaluation and access to health services, but not insurance claims.

The government's digital transformation secretariat supervises, requests information and refers cases; it has no sanction power of its own.

Who these rules reach

• Insurers: directly. Article 3(c) of the regulation applies to "Las organizaciones del sector privado, la sociedad civil, ciudadanos y la academia que integran el Sistema Nacional de Transformación Digital" (private-sector organisations, civil society, citizens and academia that form part of the National Digital Transformation System); Emergency Decree 006-2020 lists among the System's members "Organizaciones del sector privado, la sociedad civil, la academia u otros actores relevantes para una sociedad digital" (Article 9(j); read on a secondary host). The regulation's first final provision sets a one-year period for private-sector developers and implementers "Para usos de IA en los sectores de salud, educación, justicia, seguridad, economía y finanzas".
• Reinsurers: directly, as a private-sector organisation, under the same words.
• Intermediaries: directly, as a private-sector organisation, under the same words.

2. The case examined: Pacífico Seguros - Elevated

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

Why Pacífico Seguros: Pacífico's own results page says it resolves and pays up to 80% of claims cases in minutes with AI.

The question

Pacífico Seguros' 2025 integrated report says it began adapting to "el nuevo reglamento" (the new regulation) so that its use of AI is responsible, and adopted guidelines that prioritise human supervision in automated processes involving generative AI; its results page says it resolves and pays up to 80% of claims cases in minutes with AI. Peru's AI regulation, DS 115-2025-PCM, required finance-sector uses to implement its transparency and private-sector obligations by 10 September 2026 - including human supervision for AI it classes as high-risk, a list that names credit evaluation and access to health services but not insurance claims. Does Pacífico classify the AI that resolves and pays those claims as high-risk under the decree, and does its own human-supervision guideline apply to it?

In brief

Pacífico's report describes AI resolving and paying most claims cases in minutes, alongside a commitment to human supervision of generative-AI automation and an adaptation to "el nuevo reglamento" (the new regulation) - while Peru's AI decree, whose finance-sector obligations applied from 10 September 2026, reserves its human-supervision duty for high-risk uses and does not say whether insurance claims are among them.

Why this band: The question points to one firm and one decision, but the decree's human-supervision duty reaches only uses it classes as high-risk, and its list does not name insurance claims.

3. The same question for other firms in Peru

Any insurer in Peru using AI to resolve or pay claims faces the same point: whether it classes that AI as high-risk under the decree, and whether its own human-supervision rules apply to it. This entry gives no band to any firm other than Pacífico Seguros.

4. What this entry does not establish

• The 80% figure appears on Pacífico's undated web page; it was not found in the company's signed annual report.
• The report does not name the regulation it says the company began adapting to; the decree is inferred.
• The regulation's general start date (22 January 2026) is computed from a period in working days, not printed.

5. Dates ahead

• No date set: a February 2026 bill that would make the AI law's obligations enforceable under sectoral administrative regimes and create a register of high-risk AI systems.

See the Regulatory Deadline Calendar: Pending finalization / unresolved.

Sources

1. Pacífico Seguros, Memoria Integrada web page (undated). Company's own, Spanish. pacifico.com.pe
2. Pacífico Seguros, Memoria Integrada 2025 (covers 1 January to 31 December 2025; no signing date printed); PDF p. 45 ("el inicio de la adecuación al nuevo reglamento, a fin de asegurar que el uso de la inteligencia artificial sea responsable") and p. 46 (human supervision and generative AI). Company's own, Spanish. pacifico.com.pe PDF
3. Decreto Supremo N° 115-2025-PCM, El Peruano, Martes 9 de setiembre de 2025 (printed). Regulation, Spanish. gob.pe PDF
4. Congreso de la República, proyecto de ley "Ley que complementa y fortalece el marco de gobernanza, transparencia, control y responsabilidad en el uso de la inteligencia artificial", amending Law 31814, "Lima, febrero 2026" (printed); no bill number shown on the document. Bill, Spanish. congreso.gob.pe PDF

Related entries

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 PE · Corrections: none.