What do Ontario insurance brokers need in an AI policy?
RIBO expects a licensed broker in the loop and transparency about customer-facing AI. What that means for a brokerage’s AI policy, and how to show it is followed.
Ontario insurance brokerages using AI should keep a licensed broker reviewing what AI produces before clients rely on it, tell the public when customer-facing tools like chatbots or quote engines use generative AI, and audit AI used in underwriting for errors and bias. That is how RIBO’s 2025 guidance was reported. A written AI policy with recorded acceptance is the simplest way to show it.
What has RIBO said about AI?
The Registered Insurance Brokers of Ontario (RIBO) regulates the province’s licensed property and casualty brokers. In late 2024 it published research on AI in Ontario’s broker sector, carried out with the Behavioural Insights Team. In May 2025 it followed with guidance on AI use, which Canadian Underwriter reported as setting three expectations:
- A licensed broker in the loop. Generative AI use should be closely monitored by one or more licensed brokers, so a licensee can answer coverage questions and correct anything wrong or misleading.
- Transparency. Brokerages should be open with the public about customer-facing generative AI, such as chatbots and online quote engines.
- Audits. AI used in underwriting should be audited and monitored for errors and systemic bias.
RIBO has also said its existing Code of Conduct principles, such as competence, suitability and confidentiality, still apply when the work is done with AI. Check RIBO’s own guidance for the exact wording before you write your policy.
Who is responsible if AI gives a client bad information?
The guidance doesn’t settle it, but lawyers quoted in the same coverage expect the responsibility to fall on the broker, based on court decisions outside insurance. The practical answer is the same either way: a licensed person reads anything AI writes before a client relies on it.
What should an Ontario brokerage’s AI policy include?
- Which AI tools and account types are approved, and that personal free accounts are not used for client work.
- That a licensed broker approves every client-facing message AI drafts, and every coverage answer.
- How customer-facing AI is disclosed on the website, in chat and in quotes.
- What client information may never be entered, in line with the brokerage’s privacy obligations.
- Banned wording: coverage promises, “you’re fully covered”, “this claim will be paid”.
- Who audits underwriting AI, and how often.
- Recorded acceptance by every broker and staff member, against a policy version.
Our free AI use policy template has each of these as a section you can adapt.
What about federally regulated insurers?
Insurers regulated by OSFI face a separate requirement: Guideline E-23 on model risk management covers AI and machine learning models and takes effect on May 1, 2027. It applies to the insurers, not to brokerages, but carriers may expect the brokers they work with to show the same discipline.
Broker AI’s governance layer (approved tools, policy acceptance, checks on client-facing drafts, and the record) carries over to insurance brokerages as-is. The live industry pack today is mortgage; insurance wording rules are added for brokerages that sign up. General information, not legal or compliance advice. Rules differ by state, province and regulator; check with your compliance team or counsel.
Questions people ask
- Can Ontario insurance brokers use ChatGPT?
- Nothing reported from RIBO’s guidance bans it. The expectation is that a licensed broker oversees AI use and reviews what it produces, and that customer-facing AI is disclosed. Use an approved business account and keep client data out of personal ones.
- Do brokerages have to tell clients they use AI?
- RIBO’s guidance was reported as expecting transparency about customer-facing generative AI, such as chatbots and quote engines. AI used only to help a broker draft is a policy decision; many brokerages say so anyway.
- Does OSFI Guideline E-23 apply to brokerages?
- No. It applies to federally regulated financial institutions, including insurers, from May 1, 2027. Brokerages are affected through what carriers expect of them.
- Is this legal advice?
- General information, not legal or compliance advice. Rules differ by state, province and regulator; check with your compliance team or counsel.
By DisruptionIO, the team behind Broker AI. Published October 28, 2026.