Allianz Life Insurance Company of North America

Erik Nelson

Associate General Counsel, Senior Counsel

Corporate Legal

5701 Golden Hills Drive

Minneapolis, MN  55416-1297

Telephone:  763-765-7453

Erik.Nelson@allianzlife.com

www.allianzlife.com

April 15, 2022

Board of Directors

Allianz Life Insurance Company of North America

5701 Golden Hills Drive

Minneapolis, MN  55416

Re:Opinion and Consent of Counsel

         Allianz Life Insurance Company of North America

         Registration Statement on Form S-1 (File No. 333-_________)

Dear Sir or Madam:

You have requested my Opinion of Counsel in connection with the filing with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, of the Registration Statement on Form S-1 for the Individual Deferred Variable Annuity Contract to be issued by Allianz Life Insurance Company of North America, (File No. 333-_______).

I am of the following opinions:

1. Allianz Life Insurance Company of North America is a stock life insurance company organized under the laws of the state of Minnesota and is authorized to offer fixed and variable annuities and individual life insurance.

2. Upon the acceptance of purchase payments made by a Contract Owner pursuant to a Contract issued in accordance with the Prospectus contained in the Registration Statement and upon compliance with applicable law, such a Contract Owner will have a legally-issued, fully-paid, non-assessable contractual interest under such Contract, and all contractual interests of the Contract Owner are binding obligations of the Registrant.

You may use this opinion letter, or copy hereof, as an exhibit to the Registration Statement.

Sincerely,

Allianz Life Insurance Company of North America

By:    /s/ Erik T. Nelson

Erik T. NelsonAssociate General Counsel, Senior Counsel

cc:  Samantha Rawleigh