Input data and information sources
Applicants answer health questions themselves; clinicians and laboratories provide findings. The system assesses a specific person's age, occupation and circumstances.
Also known as: AI-based underwriting and pricing in life and health insurance
Insurers estimate an applicant's mortality or illness risk to determine whether to accept them and what premium to charge.
Understand the use case
Before policy inception, the model analyses health information, laboratory values and other details and assigns a risk class. US life insurer MassMutual uses such a model. BaFin states that German insurers have so far rarely used AI for this purpose.
This page describes a typical system design. Actual data flows and permissions depend on your implementation.
System design and data flows
Health answers, laboratory values, findings, occupation and circumstances arrive with the application.
Applicants answer health questions themselves; clinicians and laboratories provide findings. The system assesses a specific person's age, occupation and circumstances.
The model estimates the person's mortality or illness risk.
The model processes permitted application and risk characteristics to provide an assessment for insurance underwriting. Rating rules turn this assessment into a proposal. Acceptance, exclusions and pricing take place in the subsequent insurance process.
The model recommends a risk class and thus acceptance, a surcharge, exclusions or rejection.
The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.
The recommendation determines whether the person is insured and the premium paid throughout the policy term.
Integration determines whether the result is simply displayed, adopted after approval or written directly into a business application. These variants differ in their data flows and permissions.
Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.
9 review first9 clarify6 baseline threats
The diagram shows the typical architecture. Select a component to see what happens there and adapt its features to your system. Enable “Analysis guidance” to see which threats need reviewing for this architecture. The page's checklist continues to describe the typical case.
None yet. Each change will appear here.
In this system design: 9 to review first, 9 to clarify, 6 baseline threats.
External access: Depends on your system
To clarify
Input: Part of every AI system
Review first
Third-party content: Present
AI model: Part of every AI system
Review first
To clarify
Provider service: Depends on your system
To clarify
Training and feedback: Present
Review first
Result: Part of every AI system
Baseline for every AI system
Business application or equipment: Depends on your system
To clarify
person: Part of every AI system
Review first
Affected person: Present
Unapproved AI services: Depends on your system
To clarify
Supply chain and technical foundations: 5 baseline threats applying to every AI system
Baseline for every AI system
Credit scoring and creditworthiness assessment
Estimates whether someone will repay a loan
AI-assisted insurance claims handling
Assesses reported damage and claims rather than insurance applications
Applicants answer health questions themselves; clinicians and laboratories provide findings. The system assesses a specific person's age, occupation and circumstances.
Reinsurers and vendors supply underwriting models adopted by primary insurers.
Insurers train these models on their own application and claims data. Claims under issued policies can feed into later model versions, often only years later.
Some insurers accept favourable scores without further review; others send every recommendation to underwriters.
Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.
Assess risks and determine measures
Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.
Relate review candidates to actual data flows: what could happen, and who would be affected?
Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.
Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.
A total of 24 threats from the threat catalogue may be relevant to this use case.
Also review: whether the system disadvantages groups
Check whether selection, ranking or assessment disadvantages people with protected characteristics, such as sex, age or origin.
Underwriters may accept an unfavourable risk class without reviewing health information. The person then receives a surcharge or rejection based only on an estimate.
The model knows earlier cohorts' mortality and illness patterns. Better treatment or a changed applicant population makes risk classes inaccurate.
The model learned from many people's health data. Repeated queries can reveal whether a specific person or condition appeared in training.
Someone who knows which details worsen risk classes can deliberately alter health answers. The system then recommends different policy terms than accurate answers would produce.
Your own training or operational feedback can introduce manipulated data into training datasets.
Listed because of this characteristic
Targeted Poisoning / Label Poisoning
Falsified training labels can deliberately shift model outputs.
Listed because of this characteristic
Training data or an adopted base model can introduce hidden triggers for misbehaviour.
Listed because of this characteristic
Sensitive Information Disclosure
Confidential content can appear in answers, supplied context or logs.
Listed because of these characteristics
Exfiltration from ML Application
Protected data can leak through tools, network connections, storage or insiders.
Listed because of this characteristic
Up to 9 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system. Three of these are particularly important here and are therefore listed above.
Each Yes adds further threats to your checklist, up to 9 in total. If you cannot yet answer a question, include its threats in your review.
How your system is built
How you operate the system
Some insurers accept favourable scores without further review; others send every recommendation to underwriters.
If yes, add
An insurer setting thresholds by acceptance rate or expected claims costs directs the system towards a business objective.
If yes, add
These questions arise for almost every AI system.
Sales and application workflows often query the score through an interface.
If yes, add
If yes, add
If yes, add
If yes, add
Anyone completing an online application triggers an assessment.
If yes, add
If yes, add
Measures for the priority review areas are expanded. Each linked measure explains how to implement it.
Controls for the remaining threats are available on their pages in the threat catalogue.
For every AI system Applies since 2 February 2025.
In typical use Review trigger from 2 December 2027.
Applies if staff or appointed representatives operate or use AI systems.
Applies since 2 February 2025.
Detailed obligations
Applies if the system assesses risk or sets prices for a natural person, for example for term life or private health insurance.
Applies from 2 December 2027.
Detailed obligations
Classify your system with the quick checker All obligations in the obligations compass
Review these threats for every AI system, whatever its purpose.
If any of these features does apply to your system, add the listed threats.
Does the system generate its own text, such as answers, drafts or summaries?
The system produces a risk score or class, rather than text.
If yes, add
Does the system generate or edit images, sounds, voices or videos?
If yes, add
Does the system create new content from open-ended requests that people read, see or hear directly? Translation, reading aloud and transcription do not count.
If yes, add
Can users give the system natural language tasks that it then performs?
The model processes application details and does not accept natural language instructions.
If yes, add
Does the system search its own collection of documents or records for relevant content?
If yes, add
Does the system formulate answers from retrieved documents?
If yes, add
Does the system use a knowledge graph storing concepts and their relationships?
If yes, add
Does the system remember content from earlier conversations or tasks and reuse it later?
If yes, add
Does the system call other programs, interfaces or search services itself, even if only to read?
If yes, add
Does the system determine its next steps itself based on earlier results?
If yes, add
Does the system delegate tasks to other AI agents or incorporate their results?
If yes, add
Is the system connected to tools or data sources through the Model Context Protocol (MCP)?
If yes, add
Do documents from several customers, departments or permission groups share one search store?
If yes, add
Does the system process several input types together, such as text with images or speech?
If yes, add
Does the system generate code, scripts or database queries for further use?
If yes, add
Does the system execute programs, scripts or commands itself?
If yes, add
EU AI Act, Annex III, point 5(c)
The Act expressly lists AI systems for risk assessment and pricing of natural persons' life and health insurance in Annex III.
EIOPA, Artificial Intelligence Governance Principles, June 2021
The European insurance supervisor treats pricing and underwriting as AI application fields.
BaFin, Article on AI in banks and insurers, 1 August 2024
BaFin identifies this use among the cases listed in Annex III of the AI Act.
BaFin states that insurers have so far rarely used AI for pricing and underwriting.
Maier, Carlotto, Sanchez, Balogun, Merritt (MassMutual Data Science), Transforming Underwriting in the Life Insurance Industry, IAAI-19, AAAI 2019 According to the deployer
MassMutual data scientists describe a mortality model trained on almost one million people's applications that performs automated underwriting.
NAIC, Insurance Topics: Accelerated Underwriting
The US insurance regulator reports increasing use of external data, predictive models and machine learning and requires unfair discrimination testing.
Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured