AI Risk 2026: What Business Leaders Need to Know
The accelerating role of artificial intelligence in organizational decision making in 2026 is redefining exposure — from fraud to operational resilience. Leaders must strengthen controls, build clear accountability, and ensure their risk and insurance programs keep pace with AI‑driven threats.
Key Takeaways
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AI-enabled fraud is becoming far more convincing — AI-generated phishing shows ~54% click-through rates versus ~12% for traditional attacks — reinforcing the need for stronger verification and awareness across the organization.
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Fast-moving and fragmented AI regulation is increasing compliance pressure and the need for clear governance and board level oversight.
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AI‑related risks now span privacy, IP, operational and reputational exposures, transforming how organizations assess insurance needs and evaluate alignment with emerging loss scenarios.
Table of Contents
Artificial intelligence (AI) has moved rapidly from experimentation to enterprise‑wide adoption with advancements in Generative AI. In 2025, 88% of organizations reported using AI in at least one business function, up from 78% the previous year. This rise reflects how deeply embedded AI is now in operations and decision making.1
At the same time, risk leaders continue to rank cyber risk as the number one enterprise threat, a position it holds and is projected to maintain through 2028, according to Aon’s latest Global Risk Management Survey. AI‑driven attack techniques, including advanced phishing and deepfakes, are among the top concerns for security and risk teams — and for good reason.
AI accelerates the speed and scale of attacks, increases the complexity of operational failure and amplifies dependencies on third‑party systems. Early governance, clear accountability and resilient controls are now non‑negotiable for business leaders.
Evidence of this growing exposure is clear: The Stanford AI Index recorded 233 harmful AI‑related incidents in 2024, a 56% increase year‑on‑year, demonstrating how quickly AI‑enabled risks are expanding across sectors and geographies.2
Threat actors are also evolving their methods. According to CrowdStrike’s 2025 analysis, AI‑crafted phishing emails have shown click‑through rates of around 54%, compared with approximately 12% for traditional attacks.3 Vishing (voice phishing) incidents have also surged, and high‑profile deepfake impersonation frauds — including a widely reported $25 million case4 — highlight the operational and financial consequences of AI‑enabled deception.
Where AI Creates New Exposures
1) People and Process: Convincing Fraud at Scale
The shift: AI has transformed traditional social engineering attacks. Threat actors can now generate highly personalized emails, messages and even real‑time voice or video impersonations that imitate trusted individuals with convincing accuracy. This shift has moved fraud from isolated, opportunistic attempts to high‑volume, AI‑driven campaigns capable of bypassing standard controls and exploiting moments of pressure or ambiguity inside organizations.
What leaders should do:
- Strengthen out-of-band verification for payments and data requests.
- Require multi-person authorization for unusual transactions.
- Train employees to detect synthetic media.
- Test response plans for “live” deepfake scenarios.
2) Technology: Models, Agents and Data Pipelines can be Compromised
The shift: AI is introducing new technical pathways for compromise. In 2025, researchers uncovered malicious machine learning models (nullifAI) on a public platform5 and identified a text-to-SQL library vulnerable to prompt injection that could trigger remote code execution.6 These examples show that AI models, data pipelines and plugins require the same rigor as any software component.
What leaders should do:
- Vet external models before integration.
- Isolate model evaluation.
- Enforce strict permissions for automated agents.
- Filter inputs and outputs to reduce prompt injection and data leakage risk.
3) Ecosystem: Rising Dependency on Third-Party AI Services
The shift: Organizations are increasingly reliant on AI‑as‑a‑service providers for model hosting, inference, analytics and automation. Independent research has highlighted misconfigurations and architectural weaknesses across some fast‑scaling AI platforms, which can expose organizations to outages, data leakage or loss of service integrity.7 These dependencies introduce concentration risk and underscore the importance of supply chain resilience in AI environments.
What leaders should do:
- Include AI-specific controls in vendor reviews.
- Require transparency about training data and incident processes.
- Ensure AI suppliers feature in resilience and business continuity planning.
4) Behavior: ‘Shadow AI’ Remains a Persistent Driver of Data Leakage
The shift: Despite increased controls, employees continue to use personal AI accounts for work tasks, including uploading sensitive data. Although usage has dropped from 78% to 47% over the past year, shadow AI remains a significant source of unmonitored data exposure and compliance risk.8 Unapproved tools can easily bypass enterprise security and create blind spots in incident response processes.
What leaders should do:
- Provide safe, approved AI options.
- Set clear “do not paste” rules.
- Require dedicated credentials for AI tools.
5) Legal and Reputational: Privacy, IP and Hallucination Risk
The shift: AI has also exacerbated legal and reputational risk exposure. Organizations have faced numerous privacy‑related investigations, including over the creation of unauthorized facial recognition databases.9 Copyright disputes are increasing as publishers, artists and media companies challenge the use of their material in training datasets.10 Meanwhile, AI hallucinations — where systems generate inaccurate or fabricated content — have resulted in incorrect legal citations, misinformation and reputational damage.11
What leaders should do:
- Implement human-in-the-loop review for high-stakes AI outputs.
- Monitor legal developments and update risk and compliance processes as necessary.
Insurance in 2026: How the Market is Navigating AI‑Driven Risk
AI is reshaping risk at speed, but the insurance market is not responding with broad exclusions or sharp retrenchment. Instead, 2026 is defined by clarification, targeted adjustments and a deeper focus on how AI modifies exposure within established lines. Capacity remains available, but underwriting scrutiny is rising.
Against this backdrop, three distinct market approaches are emerging that illustrate how insurers are adapting in practice:
1) Clarifying and Selective Exclusions
Insurers are drafting AI‑related endorsements that can be deployed case‑by‑case, particularly where exposures are severe or poorly understood. Some endorsements exclude risk explicitly; others appear merely clarifying but introduce silent limitations that narrow what was previously covered. As with early “ silent cyber ,” careful policy language review is essential.
2) Affirmative Coverage Through Existing Policies
Insurers are also offering affirmative AI coverage via endorsements to cyber, E&O, media liability and EPLI programs. These can:
- Provide clarity without adding a new line of cover
- Avoid “other insurance” disputes
- Leverage deeper capacity in established markets
But not all endorsements expand cover; some introduce new exclusions or narrow the insuring clause. Clarity must not come at the expense of protection.
3) Standalone AI Products: Clear Scope, Limited Scale
New AI‑specific products — from Armilla, Munich Re’s AiSure, AXA XL, Vouch, Testudo and others — offer targeted protection for:
- Modeling underperformance or hallucination
- IP and training‑data exposures
- Regulatory compliance failures (e.g., EU AI Act)
- Data poisoning and prompt‑based attacks
Yet capacity remains limited, coverage is narrow and adoption will likely follow the slower path seen in previous digital shifts like silent cyber or cloud computing.
When developing new AI-related insurance products, markets need to be clear, deliberate and focused on their value — particularly given the pace at which these products must evolve.
Defining the Real Meaning of AI Risk
AI is not a single risk. It overlays — and amplifies — existing risks across cyber, professional services, employment, intellectual property, product liability and D&O. Like cloud and IoT, AI blurs the boundaries traditional insurance relies on. This makes governance and documentation central to underwriting confidence.
Directors & Officers Liability: AI Elevates Governance Exposure
AI is accelerating the expectations placed on boards, particularly around oversight, documentation, safety and risk assessment, and the responsible deployment of high‑impact systems. Courts and regulators increasingly expect directors to understand how and where AI is used in their organizations, ensure appropriate governance and demonstrate that risks — including model failure, data misuse and third‑party dependency — have been considered and addressed.
For boards, the most material D&O exposures include:
- Governance and oversight failures where, for example, inadequate controls, human‑in‑the‑loop processes or model testing lead to financial, operational, reputational or regulatory impacts
- Disclosure and reporting risk, particularly where AI‑driven transformation is material to financial performance or operational resilience
- Regulatory scrutiny and compliance with nascent and constantly evolving regimes across the globe, as authorities take varying approaches to evaluate how organizations manage high‑risk AI use cases, data governance, safety testing and incident reporting
- Shareholder litigation, especially arising from the governance and disclosure risks noted above, such as AI‑related misstatements accompanying losses in value, as well as claims of insufficient oversight
Insurers are already signaling increased interest in AI governance maturity within D&O underwriting — including how companies vet their public disclosures, and how boards approach oversight, integrate AI into risk registers and manage third‑party exposures.
Demand for AI‑Related Protection is Rising Sharply
Recent market research shows that more than 90% of insurance decision makers now consider AI‑driven incidents a material concern and expect insurance products to evolve accordingly.12 Underwriters increasingly expect:
- Clear evidence of AI governance
- Documented model testing
- Robust third‑party oversight
- Safeguards against data leakage and manipulation
- Scenario analysis that incorporates AI‑driven failures
Organizations that can demonstrate maturity in these areas will secure cleaner terms, greater capacity and more favorable outcomes.
Regulation and Governance: What Leaders Need to Know
AI regulation is accelerating across major markets — but in vastly different ways. In Europe, the EU Artificial Intelligence Act is progressing through phased implementation from 2025 to 2027, introducing structured obligations around documentation, monitoring, traceability and human oversight for high-risk systems.
The United States, by contrast, has moved toward a more innovation-focused approach. A new federal Executive Order sets out a “minimally burdensome” AI policy aimed at speeding deployment and strengthening national competitiveness. Rather than expanding compliance requirements, the Order seeks to streamline governance and reduce friction for U.S. companies.
With Europe tightening controls and the U.S. federal government easing them, governance expectations are diverging. Many organizations are responding by aligning internal controls to the National Institute of Standards and Technology (NIST) AI Risk Management Framework, which offers practical guidance on identifying, measuring and governing AI risk — including documentation practices, oversight points, testing disciplines and monitoring. For boards and executives, NIST provides a shared language that can unify conversations across risk, compliance, technology and insurance teams.
For leaders navigating these shifts, the takeaway is clear: AI governance must be both evidence-driven and adaptable. While regulatory trajectories differ, the expectation for traceability, assurance and transparent controls is rising globally. As Adam Peckman, Aon’s Global Practice Leader of Cyber Risk Consulting, Head of Risk Consulting & Cyber Solutions, Asia Pacific notes, “The organizations that get ahead of AI risk are the ones that treat governance as a living discipline — something that evolves with the technology, not after it.”
Building Confidence Around Emerging AI Risk
As AI reshapes fraud, operations and governance, business leaders are increasingly focused on understanding how these shifts change their exposure and what practical steps will help them stay ahead. Organizations that take a structured, evidence‑driven approach can strengthen resilience, improve decision making and ensure their insurance programs evolve in step with AI‑driven threats.
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Gaining Clarity on AI Use and Risk Exposure:
Clients are prioritizing a clearer view of where AI sits within their business, how models are developed or procured, and how AI changes operational, legal and financial exposures. Mapping use cases — and identifying where existing controls may not be designed for AI-driven failure modes — has become a foundational step for confident risk management. -
Ensuring Existing Insurance Programs Remain Fit for Purpose:
As AI adoption expands, many organizations are reviewing their cyber, E&O/PI, EPLI, crime and D&O programs to ensure coverage aligns with emerging loss scenarios. This includes understanding where cover is affirmative, where it may be silent or ambiguous, and where endorsements or exclusions could unintentionally narrow protection. -
Evaluating New Risk Transfer Options as the Market Evolves:
While standalone AI products remain narrow in scope and early in maturity, risk leaders are actively monitoring new offerings and considering when alternative structures — such as umbrella or reinsurance solutions — may be relevant. The goal is to ensure future flexibility without compromising current resilience.
Turning Insight into Strategic Advantage
Many organizations are now using scenario analysis and financial modeling tools, like Aon’s Cyber Risk Analyzer, to quantify the potential impact of AI‑enabled incidents. This helps leadership teams prioritize controls, strengthen governance, and make more informed decisions about their insurance posture.
As Brent Rieth, Aon’s Head of Global Cyber Solutions, observes, AI is “changing the risk landscape faster than traditional frameworks can adapt, and the organizations that invest early in transparent governance, scenario analysis and insurance alignment will be best positioned to adopt AI safely — and to turn risk into a source of long‑term advantage.”
1 The state of
AI in 2025: Agents, innovation, and
transformation, McKinsey
2 The 2025 AI Index Report, Stanford
University
3 CrowdStrike 2025 Threat Hunting Report: AI Becomes a
Weapon and a Target, CrowdStrike
4 ‘This happens more frequently than people realize’:
Arup chief on the lessons learned from a $25m deepfake crime, World Economic Forum
5 Malicious AI
Models on Hugging Face Exploit Novel
Attack Technique, Infosecurity Magazine
6 Black Hat: Researchers demonstrate zero-click prompt
injection attacks in popular AI agents, CSO
7 The 2025 AI Index Report, Stanford
University
8 Cloud and Threat Report: 2026, Netskope
9 UK Upper Tribunal hands down judgment on Clearview
AI Inc, ICO
10 The New York Times and Chicago Tribune sue
Perplexity over alleged copyright infringement, Engadget
11 California Court
Issues $10,000 ‘Warning’ Over
Lawyer’s ChatGPT Brief, eWeek
12 Gen AI
Risks for Businesses: Exploring the role for
insurance, Geneva Association
General Disclaimer
This document is not intended to address any specific situation or to provide legal, regulatory, financial, or other advice. While care has been taken in the production of this document, Aon does not warrant, represent or guarantee the accuracy, adequacy, completeness or fitness for any purpose of the document or any part of it and can accept no liability for any loss incurred in any way by any person who may rely on it. Any recipient shall be responsible for the use to which it puts this document. This document has been compiled using information available to us up to its date of publication and is subject to any qualifications made in the document.
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