Newsletter · Edition #50
Insurers use Claude to underwrite risk. Who will insure Claude?
Anthropic’s IPO filing · Danske Bank and AI agents · Evaluating AI agents · EU Climate Insurance Alliance · Digital Fairness Act
It has been another busy week. Personally, I am waiting for the Digital Fairness Act, which the European Commission is expected to propose on 11 November.
This edition in short:
- Anthropic’s IPO filing names underwriting insurance policies as a mission-critical use of Claude and warns that even the insurance industry as a whole may lack the capacity to cover a catastrophic AI incident.
- Danske Bank lets business customers bank through AI agents such as Claude and ChatGPT. For now, the agents can only read data.
- The Partnership on AI in Finance at the Alan Turing Institute sets out four principles for evaluating AI agents in financial services.
- The European Commission plans a Climate Insurance Alliance to narrow the natural catastrophe protection gap, with first measures due by the end of 2027.
- What the Digital Fairness Act is expected to target, and why every bank, insurer, investment firm and payment provider should follow it.
- AmTrust acquires Wakam, which can write new business again a month after the French supervisor barred it from doing so.
- 1st Central launches Motivo, UK motor insurance that customers buy and manage through an AI assistant.
But first, some personal news.
I made my AI library public. For quite some time I have kept a private list of every paper financial supervisors publish on AI. It was only ever meant for me, a working tool for my advisory work and teaching. Recently I shared it with participants of the Cambridge course on AI in financial services, where I am a mentor, and thought it might be useful to many more people: supervisors, compliance and risk teams, boards, founders, anyone trying to keep up. So I cleaned it up and made it public.
It has 52 documents from 2023 to 2026:
- International bodies: FSB, IOSCO, IAIS, OECD, IMF, World Bank and BIS.
- European supervisors: EBA, EIOPA, ESMA and ECB.
- National supervisors: MAS, HKMA, FCA, FINMA, OSFI, APRA, BaFin, NYDFS and more.
Every entry has the date, the issuer, the type of document, the sector, one sentence on what it does and a link to the original. Putting it together, the pace surprised even me: in October 2026 alone, the FSB, MAS, the HKMA and the FCA all published.
Is something missing? Is there a document you would add? And honestly, is a list like this helpful at all? Reply to this email and let me know; I will keep the library updated. Browse the library.
What Anthropic’s IPO filing says about insurance
On 26 October 2026 Anthropic, the company behind Claude, publicly filed its registration statement (Form S-1) with the US Securities and Exchange Commission for a planned listing on Nasdaq. Among its examples of mission-critical uses of Claude, the first it names is underwriting insurance policies. The same document warns that a catastrophic AI incident could exceed the capacity of any single insurer, and possibly of the insurance industry as a whole.
It is rare to see an AI developer say so plainly that the insurance industry may not be big enough for the risk it is creating, while counting that same industry among its most important customers.
Read my summary of the filing.
Danske Bank lets business customers bank through AI agents
On 21 October 2026 Danske Bank announced that business customers can now bank through AI agents such as Claude and ChatGPT. Danske says it is the first bank in the Nordic countries to offer this. Customers connect their own AI tool to their banking data through a Model Context Protocol (MCP) server and can ask for balances, transaction analysis and cash-flow forecasts.
For now, the agents can only read data, and the customer is responsible for what its agent does. The harder questions come when agents start to act: how consent and strong customer authentication work when an agent initiates a payment, and who is liable when it gets something wrong. EU payment law has no specific rules for AI agents yet.
Read my summary of Danske Bank’s launch.
The Alan Turing Institute sets out four principles for evaluating AI agents in finance
In October 2026 the Partnership on AI in Finance (PAIF) at the Alan Turing Institute published a report, Evaluation for Assurance of Agentic AI Systems in Financial Services, written with practitioners from Aviva, BNY, HSBC and Mastercard. AI agents plan, use tools and act across multiple steps on their own, and they are moving into regulated finance faster than our ways of testing them. Once they leave the back office and start touching customers, “it worked in the pilot” is no longer enough.
The report offers four principles for evaluation programmes:
- Use the modularity of agentic systems to test both the components and the full end-to-end flow.
- Match evaluation intensity to deployment risk.
- Strengthen automated evaluation methods and adopt them responsibly.
- Focus on evidence that actually drives governance decisions.
The message is simple: move from ad hoc testing to systematic assurance.
The European Commission plans a Climate Insurance Alliance to narrow the protection gap
On 27 October 2026 the European Commission presented its Framework for Climate Resilience. Part of it is a Climate Insurance Alliance that will bring together insurers, reinsurers, intermediaries, policyholders, risk modellers, investors, EIOPA and public authorities. By the end of 2027 it is to propose a first set of measures in three areas: insurance uptake, risk prevention and insurance capacity.
The Alliance is a platform for cooperation, not a new legal body or fund, and its membership and working arrangements are not yet known. My overview covers how it will work, EIOPA’s new Observatory for Catastrophe Risk Insurability and how the Alliance’s work on public-private partnerships relates to the 2024 EIOPA and ECB proposal for an EU-level public-private reinsurance scheme.
Read my overview of the Alliance.
The European Commission is expected to propose the Digital Fairness Act on 11 November
On 11 November the European Commission is expected to propose the Digital Fairness Act. It is a consumer law, but it builds on consumer rules that already apply to banks, insurers, investment firms and payment providers, so every one of them should follow it closely.
In 2024 the Commission reviewed EU consumer law and concluded that it only partly protects consumers online. It put the harm at a minimum of EUR 7.9 billion a year. A 2022 Commission study found at least one dark pattern on 97% of the most popular websites and apps. In her State of the Union address in September, President von der Leyen confirmed the proposal for this autumn.
The act is expected to target dark patterns, addictive design, influencer marketing, unfair personalisation (including prices based on personal data), subscription traps and misleading prices. The proposal is the start, not the end. The rules will take years to apply, but firms that map their digital customer journeys now will not be caught out later.
I can help you understand the background, what we already know and the stakeholder positions already on the table; follow the file as it develops; and assess what the Digital Fairness Act means for your products, apps, marketing and distribution. If you want to discuss it, reply to this email.
Read the Commission’s page on the review of EU consumer law.
On 26 October 2026 AmTrust International announced it has acquired Wakam, the B2B2C carrier behind many of Europe’s MGA and embedded insurance programmes. Under AmTrust ownership, Wakam says it is fully capitalised and can again write new business and renew policies in all jurisdictions, a month after the French supervisor ACPR barred it from doing so. Read my take.
On 21 October 2026 UK insurer 1st Central Group launched Motivo, an agentic AI motor insurance solution built with Microsoft. Its AI assistant, KAI, helps customers buy cover, change their policy and manage payments, 24/7, with insurance specialists stepping in when needed. For now it is sold only through Confused.com, and claims support comes later. Read my summary.
in economic losses from climate extremes in the EU each year, on average over the past four years, according to the European Commission. In the 1980s the figure was EUR 8.6 billion. Historically, only around a quarter of natural catastrophe losses in the EU have been insured.
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Andres Lehtmets helps financial firms and supervisors make new technology and new rules work together. Former Senior InsurTech Expert at EIOPA.