The pace has picked up. ASIC has written to every AFS licensee about AI, insurance brokers included. Its governance review named insurance among the sectors moving faster than their risk frameworks. This month the government stood up an Office of AI and flagged national standards for legislation next year. None of that last part touches a brokerage yet, but my honest reading is that it will not stay that way. Claims handling, automated renewals, AI tools your team started using without anyone signing off. It all reaches your desk eventually.
A note on independence before anything else: I don’t sell software and I take no fees from anyone who does. When I write about the platforms brokers run, nothing changes for me whichever one you use.
What applies to you right now
The nearest obligation is the Privacy Act’s automated decision-making disclosure, live from 10 December 2026. It is about decisions, not tools. If a computer program makes a decision that could significantly affect someone, or does something substantially and directly related to making one, your privacy policy has to say so. For a brokerage the question lives in three client-facing places: placement, renewals, and claims. Claims deserves particular care, because claims files routinely hold health and injury information, and handling sensitive information can bring a firm within the Privacy Act regardless of turnover. And the obligation is not only about clients. If your recruitment software ranks or filters applicants before anyone reads a CV, that is a decision about a person too.
Being in scope is a disclosure to write, not a feature to switch off. And the same feature can be in scope at one brokerage and out at the next, because the answer lives in the process around it, not the software.
Where to start
Run JAVLN?
Using JAVLN? What the Privacy Act ADM rules mean before 10 December walks the platform’s own features through the disclosure test, with worked examples across placement, renewals and claims.
Want to see what an assessment produces?
A sample ADM assessment, worked through a fictional brokerage, shows the register, the determinations and the policy notes a real engagement delivers.
Wondering what the regulators are actually saying?
Regulator AI letters: what they mean for your firm separates what has been asked of you from what has been asked of the insurers you place with.
Thinking about renewal season?
AI is changing your business insurance: what to look for at renewal covers the questions worth asking before terms roll over.
More for insurance broking
Where the guidance stops
Everything above is written to be used without me. It stays deliberately short of advice, because whether a specific feature at your brokerage is in scope depends on how your firm works, and I don’t advise on firms I haven’t looked at. That boundary is where the paid work begins. The ADM assessment maps your decisions, your software and your obligations for a fixed AUD 2,500, and a Decision Review answers one specific question, a vendor pitch, a feature, a use case, for AUD 1,500. If AI questions come up most months, the retainer exists for that.