National · NAIC Big Data and Artificial Intelligence (H) Working Group
NAIC AI Systems Evaluation Tool (2026 Pilot)
This is the moment guidance becomes examination. The NAIC AI Systems Evaluation Tool gives regulators a structured way to gather, in a market-conduct or financial-exam context, how extensively an insurer uses AI, its governance and risk-mitigation practices, detail on high-risk AI models, and the data feeding those systems. A 12-state pilot runs March to September 2026, with adoption targeted at the NAIC Fall National Meeting in 2026. It puts a live calendar date on AI-governance exam risk.
What it covers
The NAIC AI Systems Evaluation Tool is being developed by the Big Data and Artificial Intelligence (H) Working Group as a guide for state regulators to use in market-conduct, financial-analysis, or financial-exam contexts. It gathers information about the extent and use of AI by an insurer, the insurer's governance and risk-mitigation practices, detail on potentially high-risk AI models, and the data used as inputs into AI systems.
A pilot with 12 participating states runs from March 2026 to September 2026, covering property/casualty, life, and health insurers and focusing on domestic insurers, applying proportionality so that high-risk AI systems receive more scrutiny. Based on the pilot, the Tool is anticipated to be adopted at the 2026 Fall National Meeting. The pilot turns principle-based AI guidance into a concrete examination instrument with a defined timeline.
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