FIJISHI EPL

Fijishi Jurisdiction Index: AI in Insurance Decisions · 2026 edition · Published 12 October 2026

By Akhil Sharma and Preethi Sharma, Fijishi.

What the Index is

The Fijishi Jurisdiction Index: AI in Insurance Decisions is an annual, independent review of how jurisdictions govern AI used in insurance decisions.

It has 38 entries across 34 jurisdictions; the United States counts as one jurisdiction with five entries.

Each entry sets a jurisdiction's own published rules against the published record of AI use in its insurance market, and ends in one sourced question that the public record does not yet answer.

It is free to read, and no one pays to appear.

Who it is for

It is for insurers, reinsurers and intermediaries operating in a covered jurisdiction who want to see how its rules meet the AI in their decisions, and for anyone who studies or reports on how AI in insurance is governed.

Why we built it

We explain why in Who we are, independence and right of reply.

Why companies are named

Where an entry names a company, it is because the company's use of AI is on the public record.

That account shows the entry's question is live in its jurisdiction.

The company is the case examined, not the boundary of who the rules reach, and the band applies to that case alone.

How to read an entry

The tier describes the jurisdiction, and applies to every firm there. The band applies only to the case examined. Named companies are examples chosen because their AI use is on the public record - in all but one case, in their own publications; they are not the only firms the rules reach.

At a glance (entries, not jurisdictions; the five United States entries sit in two tiers)

Tier	Exposed	Elevated	Watching	Contained	Entries
A - Specified and enforced	2	8	2	0	12
B - Enforcement stated, not yet live	1	2	1	3	7
C - Specified, not yet enforced	0	4	0	3	7
D - Not yet specified	0	3	0	9	12
All	3	17	3	15	38

Jurisdictions under each tier

• Tier A (12 entries): China, Germany, Malaysia, Malta, Peru, Qatar, Switzerland, United Arab Emirates (DIFC), United States (California), United States (Colorado), United States (New York), United States (Texas).
• Tier B (7 entries): Australia, Canada, European Union (EU-wide), Ireland, Luxembourg, South Korea, Taiwan.
• Tier C (7 entries): Bermuda, Japan, Mauritius, Singapore, Thailand, United Arab Emirates (mainland), United Kingdom.
• Tier D (12 entries): Bahrain, Cameroon, Cayman Islands, Hong Kong, India, Indonesia, Israel, Nigeria, Pakistan, Saudi Arabia, South Africa, United States (Federal).

What the 38 entries show together

1. All 7 company cases in Tier C or D jurisdictions are Elevated: Hong Kong, India, Japan, Saudi Arabia, Singapore, the United Arab Emirates (mainland) and the United Kingdom.
2. Of the 23 company cases, 11 concern AI in underwriting or pricing, 8 concern AI in claims or claim authorisation, 1 concerns both, 2 concern AI agents that deal with customers, and 1 concerns AI systems in general.
3. In 6 of the 23 company cases, the company's own account, as quoted in the question, says that a person keeps the final decision or oversight: Aviva, Evolent Health, ICICI Lombard, Pacífico Seguros, Prudential Hong Kong and QBE.
4. In 5 entries, the rule the question turns on is a data-protection rule on automated processing or autonomous systems rather than an insurance rule: Cameroon, Canada (Quebec), Mauritius, South Africa and the United Arab Emirates (DIFC).
5. In 5 entries, the open question is which of two named authorities, or sets of authorities, acts: Cameroon, Mauritius, Pakistan, Saudi Arabia and South Africa.
6. Of the three EU member states in the Index whose entries turn on the EU AI Act's transparency duty, one (Germany) has a national authority designated for insurers' AI systems, and in two (Ireland and Luxembourg) the entry asks whether any authority can act on that duty yet.
7. In 14 entries, each in a different jurisdiction, the binding rule shown in the entry's Reach block reaches reinsurers directly. In 6 it names them, or an insurance class that includes them: Bermuda, Cameroon, Germany, Indonesia, Malaysia and Nigeria. In 8 it reaches any firm, reinsurers included, by what the firm does or by a wider group the firm belongs to: Canada (Quebec), Cayman Islands, Ireland, Japan, Luxembourg, Peru, South Africa and the United Arab Emirates (DIFC).

Directory (A→Z; "Last verified" shows the date each entry was checked)

Code	Jurisdiction	Tier	Band	Case examined / question to	Last verified	Entry
AU	Australia	B	Watching	QBE Insurance Group	[date checked]	AU
BH	Bahrain	D	Contained	Question: the Central Bank of Bahrain	[date checked]	BH
BM	Bermuda	C	Contained	Question: the Bermuda Monetary Authority	[date checked]	BM
CM	Cameroon	D	Contained	Question: the regional insurance supervisor and the data protection authority	[date checked]	CM
CA	Canada	B	Exposed	Intact Insurance Company	[date checked]	CA
KY	Cayman Islands	D	Contained	Question: the Cayman Islands Monetary Authority	[date checked]	KY
CN	China	A	Elevated	ZhongAn Online	[date checked]	CN
EU	European Union (EU-wide)	B	Contained	Question: EIOPA	[date checked]	EU
DE	Germany	A	Exposed	ERGO Group	[date checked]	DE
HK	Hong Kong	D	Elevated	Prudential Hong Kong Limited	[date checked]	HK
IN	India	D	Elevated	ICICI Lombard	[date checked]	IN
ID	Indonesia	D	Contained	Question: OJK	[date checked]	ID
IE	Ireland	B	Contained	Question: the Central Bank of Ireland	[date checked]	IE
IL	Israel	D	Contained	Question: the Capital Market, Insurance and Savings Authority	[date checked]	IL
JP	Japan	C	Elevated	Meiji Yasuda Life	[date checked]	JP
LU	Luxembourg	B	Contained	Question: the Commissariat aux Assurances	[date checked]	LU
MY	Malaysia	A	Watching	Allianz Malaysia	[date checked]	MY
MT	Malta	A	Exposed	MAPFRE Malta	[date checked]	MT
MU	Mauritius	C	Contained	Question: the Financial Services Commission and the data protection authority	[date checked]	MU
NG	Nigeria	D	Contained	Question: NAICOM	[date checked]	NG
PK	Pakistan	D	Contained	Question: SECP and the Government of Pakistan	[date checked]	PK
PE	Peru	A	Elevated	Pacífico Seguros	[date checked]	PE
QA	Qatar	A	Elevated	QIC Group	[date checked]	QA
SA	Saudi Arabia	D	Elevated	Tawuniya	[date checked]	SA
SG	Singapore	C	Elevated	MSIG Insurance (Singapore)	[date checked]	SG
ZA	South Africa	D	Contained	Question: the Information Regulator and the FSCA	[date checked]	ZA
KR	South Korea	B	Elevated	Samsung Fire & Marine (press-reported account)	[date checked]	KR
CH	Switzerland	A	Elevated	Swiss Re	[date checked]	CH
TW	Taiwan	B	Elevated	Cathay Century Insurance	[date checked]	TW
TH	Thailand	C	Contained	Question: the Office of Insurance Commission	[date checked]	TH
AE-DIFC	United Arab Emirates (DIFC)	A	Watching	Atradius (DIFC)	[date checked]	AE-DIFC
AE	United Arab Emirates (mainland)	C	Elevated	Sukoon Insurance	[date checked]	AE
UK	United Kingdom	C	Elevated	Aviva	[date checked]	UK
US-CA	United States - California	A	Elevated	Roadzen	[date checked]	US-CA
US-CO	United States - Colorado	A	Elevated	Ethos Technologies	[date checked]	US-CO
US-FED	United States - Federal	D	Contained	Question: federal reach over state insurance AI rules	[date checked]	US-FED
US-NY	United States - New York	A	Elevated	Lemonade Insurance Co.	[date checked]	US-NY
US-TX	United States - Texas	A	Elevated	Evolent Health	[date checked]	US-TX

Dates ahead

See the Regulatory Deadline Calendar: fijishi.com/viewforum.php?f=9.

PDF and citation

PDF edition: [Zenodo link, added on launch day].

Cite as: Sharma, A. and Sharma, P. (2026). Fijishi Jurisdiction Index 2026: AI in Insurance Decisions. Fijishi, Pune. 12 October 2026. DOI: [added on launch day].


Contact and right of reply

Write to indexreport.protocol@fijishi.com.

Any named party may reply, and with its agreement the reply is published in full below its entry, dated.

Corrections are logged in Corrections and new evidence.