EU AI Act AI Literacy Practices in insurance

Introduction

Under the EU AI Act, insurers and intermediaries that provide or deploy AI systems must ensure adequate AI literacy among staff and relevant stakeholders. This requirement is flexible to accommodate the diversity and complexity of AI tools.

To support AI literacy, the European Commission has launched a Living Repository, an evolving collection of best practices. Among the contributors are Gjensidige and Generali, which share their AI use cases and training initiatives.

Generali's AI Literacy Approach

Generali integrates AI across its value chain—from product design to claims management—and has developed a global AI literacy program as part of its digital upskilling efforts. Established in 2019, this program consists of:

1. WeLearn, a global e-learning platform offering tiered AI training, from foundational courses for all employees to intermediate and advanced modules for those directly interacting with or developing AI systems.
2. New Roles Schools, internal academies in partnership with universities, training specialists in AI-driven roles such as Data Scientists, AI Business Translators, and Actuaries.

Training is industry-specific, incorporating real-world AI applications within Generali. Employees must pass assessments to progress, ensuring alignment with their expertise. It has fostered a culture of continuous learning and strengthened collaboration with universities and research centers.

Gjensidige's AI Literacy Approach

Gjensidige, both a provider and deployer of AI, primarily uses AI for low-risk applications under the EU AI Act but also operates high-risk AI systems internally. Its AI literacy efforts focus on employees, with plans to extend training to insurance agents and claims processors. The company is also exploring ways to educate customers on AI’s impact through accessible materials.

AI training is role-based and mandatory for all employees, beginning with foundational e-learning and progressing to specialized modules. Analysts receive training in model risk management and data governance, while compliance and security teams focus on broader AI risk management. End users in claims management undergo system-specific training.

Gjensidige employs a multi-channel training approach, ensuring accessibility for employees with varying technical expertise. AI literacy is assessed during recruitment and onboarding, and training materials remain available via a central knowledge base linked to AI system providers. The company maintains an AI registry, detailing each system's purpose and guidelines for responsible use.

Both insurers demonstrate proactive AI literacy initiatives, aligning with regulatory expectations and fostering a workforce equipped to engage with AI responsibly.