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. |
| Case examined | Intact Insurance Company - machine-learning pricing in Quebec personal lines |
| Band for this case | Exposed |
| Rules reach | Insurers: directly · Reinsurers: directly · Intermediaries: directly |
| Last verified | [actual date of the launch-window check] |
Canada's insurance regulators have issued AI rules that take effect on 1 May 2027: OSFI's Guideline E-23 on model risk management, which brings AI and machine-learning methods into the definition of a model, and the Autorité des marchés financiers' Guideline on the use of AI for insurers authorised in Quebec.
In Quebec, section 12.1 of the Act respecting the protection of personal information in the private sector has been in force since 22 September 2023. It requires a business to inform a person when a decision about them is based exclusively on automated processing, and to offer a review by a staff member.
Who these rules reach
- Insurers: directly. Section 12.1 applies to "Toute personne qui exploite une entreprise et qui utilise des renseignements personnels afin que soit rendue une décision fondée exclusivement sur un traitement automatisé" (any person carrying on an enterprise who uses personal information so that a decision is made based exclusively on automated processing).
- Reinsurers: directly, under the same words, where a reinsurer makes such a decision about a person.
- Intermediaries: directly, under the same words, where an intermediary makes such a decision about a person.
This band describes how clearly the rules meet the AI use that Intact Insurance Company has itself published. It is not a finding that Intact Insurance Company has breached any rule.
Why Intact Insurance Company: Intact Financial's 2025 Annual Report states that machine-learning models power most of its Canadian personal-lines volume.
The question
In briefIntact Insurance Company sells personal insurance in Quebec, and Intact Financial's 2025 Annual Report says: "State-of-the-art machine learning models now power more than 90% of Personal lines volume and 60% of Commercial lines in Canada as we continue to advance pricing sophistication." In Quebec, section 12.1 of the province's Act respecting the protection of personal information in the private sector requires a business that uses personal information to render a decision based exclusively on automated processing to inform the person no later than when it informs them of the decision, to give them on request the principal factors and parameters that led to it, and to let them submit observations to a staff member able to review it. Quebec's insurance regulator, the Autorité des marchés financiers, has issued a Guideline on the use of artificial intelligence (March 2026) which, from 1 May 2027, applies to insurers authorised in Quebec and says that where a client is subject to a decision made or recommended by an AI system, the institution should explain the decision clearly and simply (section 8.3). Where one of these models determines the premium offered on a Quebec personal-lines policy, does Intact treat that as a decision based exclusively on automated processing under section 12.1, of which it informs the Quebec customer now, or as a decision in which a person takes part?
Why this band: The rule in the question binds, covers decisions made solely by automated processing, and has a fixed date, and the question points to one firm, one decision and one duty.Intact, which sells personal insurance in Quebec, says machine learning now powers more than nine-tenths of its Canadian personal-lines volume. In Quebec, privacy law already requires a business to tell people when a decision about them is made solely by automated processing and to offer a human review, and the province's insurance regulator will expect insurers to explain AI decisions to clients from May 2027. Intact has not publicly said whether, where these models determine a Quebec premium, it treats that as an automated decision under Quebec law.
3. The same question for other firms in Canada
Any business in Quebec that sets a premium or makes another insurance decision about a person solely by automated processing faces the same point: whether it treats that decision as falling under section 12.1, and informs the person no later than when it informs them of the decision. This entry gives no band to any firm other than Intact Insurance Company.
4. What this entry does not establish
- Whether Intact's models determine individual Quebec premiums, or whether a person takes part in any pricing decision. The question is conditional, and this entry says nothing either way.
- The commencement date of section 12.1 is taken from the history notes on LegisQuébec, read through a processed copy.
- The annual report's figure covers Intact's Canadian personal lines as a whole, not Quebec alone.
- 1 May 2027: OSFI Guideline E-23 and the AMF Guideline on the use of AI take effect.
Sources
- Intact Financial Corporation, 2025 Annual Report (MD&A dated February 10, 2026, printed). Company's own. intactfc.com PDF
- Intact Insurance Company, Quebec personal-insurance page (undated; observed 27 September 2026). Company's own. intact.ca
- Act respecting the protection of personal information in the private sector (CQLR c. P-39.1), s.12.1, LegisQuébec, up to date to 10 June 2026 (printed). Statute, French. legisquebec.gouv.qc.ca
- Commission d'accès à l'information du Québec, Principaux changements apportés par la Loi 25 (undated). Regulator. cai.gouv.qc.ca
- Autorité des marchés financiers, Ligne directrice sur l'utilisation de l'intelligence artificielle, March 2026 (printed). Regulator, French. lautorite.qc.ca PDF
- OSFI, Guideline E-23 – Model Risk Management (2027), published September 11, 2025; effective May 1, 2027 (printed). Regulator. osfi-bsif.gc.ca
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 CA · Corrections: none.