The Autorité confirms a clear trend: any use of AI must now be regulated, explainable, and focused on the fair treatment of clients. This includes indirect uses such as sales support tools, comparison platforms, and recommendation systems. 

For the members of the Chambre, it is no longer enough simply to use a technological tool. Professionals must also understand how it works, its limitations, the risks associated with it, and its potential impacts. 

Below are three key elements of the Guideline that you need to know and that impact your work. 

1. A Designated Officer Within the Institution or Insurance Firm

Each insurance firm or insurer must appoint a member of senior management was the officer responsible for all AI systems used within the organization. This means that decisions involving AI, including those affecting client files, must be tracked, justified, and overseen at a senior level within the institution. 

For representatives, this may result in stricter internal policies governing the use of AI systems, particularly when AI is involved in decisions or recommendations relating to a client’s file. Additionally, the representatives must know who the designated AI officer is within their organization so they can consult that person when questions arise regarding the use of AI systems.

2. Risk Management: An Inventory of AI Systems

The Guideline requires financial institutions to maintain a centralized inventory of all AI systems and assign each one a risk rating to be reviewed periodically. The higher the risk associated with a system, the stricter the controls and oversight must be.

As a result, analytical tools provided to insurance or financial planning professionals will be subject to increased and documented monitoring. Professionals must understand the risks associated with these tools, their operational and usage limitations, and the mitigation measures that apply in order to use them properly.

3. Strengthened Transparency Obligations Toward Clients

The Guideline emphasizes several key principles that directly affect the relationship between representatives and clients:

• Clients must be informed when they are interacting with an AI system. 
• Clients must be able to request human intervention during a transaction when needed. Organizations must therefore provide appropriate mechanisms to ensure a person can intervene in a timely manner when requested.
• Any content generated with the assistance of an AI system must include a disclosure indicating that AI was used.
• Any decision made by, or recommendation generated by, an AI system concerning a client must be explainable in clear and simple language. 
• Representatives must validate AI-generated results and ensure that AI tools do not create discriminatory outcomes or biases affecting clients. 

This is perhaps the most practical aspect of the Guideline for representatives, who are often the first point of contact when it comes to conveying information to clients. Representatives become a vital link in ensuring the transparency required by the Guideline. Understanding how an AI system operates, being able to explain its general logic without technical jargon, and directing clients to the appropriate resources in the event of a disagreement: this is what this new context requires of you.  

Consistent with its mission, the Autorité’s regulatory framework for AI is not intended to slow innovation, but rather to ensure that it benefits the clients. For insurance professionals and firms, this means developing a stronger understanding of the tools they use and strengthening professional practices. As 2027 approaches, understanding the AI systems used within your organization, as well as their limitations, will become a key professional competency. 

What You Can Do Now

Here are some concrete steps to consider between now and the guideline’s effective date on May 1, 2027:

• Review the tip sheet and guide developed by the Chambre de l’assurance and available on its website. Consider completing the compliance training course “Utiliser l’IA : vers une pratique responsible” availabe in French (here for professionals in damage insurance and here for life and health insurance professionals). 
• Speak with your employer and partner insurers. Ask which AI systems are currently being used and what plans are in place to comply with the Guideline. 
• Develop a clear understanding of the environment in which you operate. This is a critical first step. 
• Review how you communicate with clients. If an automated tool contributed to a decision, can you explain it in simple terms? Anticipating these conversations strengthens both your advisory role and builds your client’s trust. 
• Include digital literacy in your continuing education activities. The Chambre de l’assurance offers a training activity on artificial intelligence. 
• Document your practices. When AI-assisted decisions or recommendations are involved, maintaining proper records becomes an important professional best practice.