The DAV advocates for a legal clarification in the AI Act to distinguish classical statistical methods from the AI definition.

With Regulation (EU) 2024/1689 laying down harmonized rules on artificial intelligence (hereinafter: the AI Act), the European Union has, for the first time, established a horizontal legal framework for AI systems. The European Commission’s guidelines on the definition of an AI system, set out in Communication C(2025) 5053 final of 29 July 2025, are intended to provide practical guidance for the interpretation of Article 3(1) of the AI Act. From an actuarial perspective, however, considerable room for interpretation remains, particularly with regard to classical statistical methods such as linear and logistic regression as special cases of Generalized Linear Models (GLMs), and GLMs as special cases of Generalized Additive Models (GAMs). These methods have formed part of the standard methodological toolkit in actuarial science for the past three decades and have proven their value in decision-critical applications such as pricing and underwriting. Actuaries receive extensive training in their use and thereby help ensure a high degree of explainability, transparency, and freedom from discrimination.

The German Association of Actuaries (DAV) takes this remaining interpretative uncertainty as an opportunity to set out its professional position: classical statistical methods should not be classified as AI systems within the meaning of Article 3(1) of the AI Act. This statement substantiates that position on the basis of the defining characteristics of AI systems themselves and calls upon the European Commission to provide a clear and explicit clarification.