At a glance
| Jurisdiction tier | Tier B - Specified; enforcement stated, not yet live. AI is specified as for Tier A, and a mechanism to check or sanction it has been stated but is not yet shown to be live. |
| Question to | the Central Bank of Ireland - enforcement of the AI Act's transparency duty |
| Band for this question | Contained |
| Rules reach | Insurers: directly · Reinsurers: directly · Intermediaries: directly |
| Last verified | [actual date of the launch-window check] |
The EU AI Act's duty to tell people they are interacting with an AI system (Article 50) has applied since 2 August 2026. Ireland's Regulation of Artificial Intelligence Act 2026 has been in operation since 31 July 2026; section 133 lists Article 50 transparency infringements among those for which the Central Bank may impose fines through its own inquiry procedures.
The Central Bank's designation as a market surveillance authority, by S.I. No. 366 of 2025, is for the purposes of Article 74(6), which concerns high-risk AI systems used by financial institutions. The high-risk rules for those systems apply from 2 December 2027.
Who these rules reach
- Insurers: directly, where the insurer is the provider. Article 50(1): "Providers shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system". Read on a secondary host.
- Reinsurers: directly, where the reinsurer is the provider, under the same words.
- Intermediaries: directly, where the intermediary is the provider, under the same words.
This band describes how far the published record answers the question put to the Central Bank of Ireland. It is not a finding that the Central Bank of Ireland, or any firm it oversees, has fallen short of any rule.
Why the question goes to the Central Bank of Ireland: The question concerns the Central Bank's own remit, and this entry relies on no single company's account.
The question
In briefIreland's Regulation of Artificial Intelligence Act 2026 (No. 31 of 2026), dated 21 July 2026, has been in operation since 31 July 2026. Section 133 sets out the AI Act fines the Central Bank may impose where the Central Bank Act 1942 procedures are invoked, including for "an infringement of transparency obligations for providers and deployers pursuant to Article 50". The Central Bank's designation as market surveillance authority, in S.I. No. 366 of 2025, is "for the purposes of Article 74(6)" of the AI Act, a provision concerning high-risk AI systems used by financial institutions. The high-risk rules for Annex III systems apply from 2 December 2027; the Article 50 duties have applied since 2 August 2026. The Central Bank's own survey of 53 (re)insurers, published in March 2026, found AI in claims, customer service and other functions, with a small minority of uses consumer-facing. For an Irish insurer's customer-facing AI system that is not high-risk, does the Central Bank supervise compliance with Article 50 now, or only for systems that fall under Article 74(6)?
Why this band: No company's own account could be tested, so the question rests on the statute, the statutory instruments and the Central Bank's own publications.Ireland's AI Act enforcement law has been in operation since 31 July 2026. It lets the Central Bank fine firms for breaches of the AI Act's transparency duties, which have applied since 2 August 2026. The Central Bank's formal designation, made by statutory instrument in 2025, refers to the AI Act's provision for high-risk systems used by financial institutions, and the high-risk rules for those systems apply from December 2027. We found no Central Bank statement saying whether it supervises the transparency duties for Irish insurers' other customer-facing AI now.
3. What the open question means for firms in Ireland
Until the Central Bank answers, an Irish insurer running a customer-facing AI system that is not high-risk has no published statement on whether the Central Bank has supervised its Article 50 duty since 2 August 2026. This entry gives no band to any firm.
4. What this entry does not establish
- Article 74(6) was read on a secondary host, not on EUR-Lex.
- The Central Bank Act 1942 provisions to which section 133 refers were not read.
- Whether any Irish insurer's customer-facing AI meets Article 50. This entry says nothing either way.
- 2 December 2026: the grace period for Article 50(2) marking ends.
- 2 December 2027: the AI Act's high-risk rules for these systems apply.
- No date set: any Central Bank statement on Article 50, or amendment to S.I. No. 366 of 2025.
Sources
- Regulation of Artificial Intelligence Act 2026 (No. 31 of 2026), 21 July 2026 (printed). Statute. irishstatutebook.ie
- S.I. No. 366 of 2025, European Union (Artificial Intelligence) (Designation) Regulations 2025, 25 July 2025 (printed). Statutory instrument. irishstatutebook.ie
- S.I. No. 403 of 2026, Regulation of Artificial Intelligence Act 2026 (Commencement) Order 2026, 31 July 2026 (printed). Statutory instrument. irishstatutebook.ie PDF
- Regulation (EU) 2026/1744 of 8 July 2026, Official Journal of the EU, 24 July 2026 (printed). EU law. EUR-Lex
- Department of Enterprise, Tourism and Employment, news release, 30th July 2026 (printed). Government. enterprise.gov.ie
- Central Bank of Ireland, Regulatory & Supervisory Outlook, 26 February 2026 (printed). Regulator. centralbank.ie PDF
- Central Bank of Ireland, Insurance Newsletter, March 2026 (printed), "Survey on Artificial Intelligence". Regulator. centralbank.ie PDF
- European Commission, FAQ on transparency obligations under Article 50 of the AI Act, last updated 24 July 2026 (printed). EU law (Commission guidance). digital-strategy.ec.europa.eu
- Regulation (EU) 2024/1689 (AI Act), Articles 50(1) and 74(6), read on a secondary host. EU law. artificialintelligenceact.eu
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