PensionsEurope submitted on 13 September 2024, its answer to the Commission consultation on AI in the financial sector.
We indicated that there are fewer AI use cases in our sector than in the others as the IORPs landscape is very heterogeneous, with many small entities but also very big in some cases, dealing first and foremost with members and beneficiaries as well as customers.
However, AI is being used for 1) the dialogue between pension funds and members and beneficiaries through Chatbots, 2) asset management optimization, and 3) employer use cases. Furthermore, there are no AI pension use cases that would be categorised as unacceptable and high-risk as outlined in the AI Act. Risks of bias and discrimination are low in pension AI use cases.
We would also like to emphasise that, a principle-based, risk-based, and stakeholder-driven approach is the best way to get to effective controls that are relevant for pension provision. To tailor obligations as much as possible to pension providers, any legislation of AI in the financial sector should take the form of a sectoral approach for IORPs rather than a horizontal one.
