National · NAIC
NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers
The NAIC's model framework setting out how it expects insurers to govern their use of AI. It sets expectations rather than a checklist: insurers are expected to maintain a written AI program covering governance, risk management, internal audit, consumer protection, and oversight of third-party AI vendors. It is principle-based, so compliance is judged on reasonableness, not a fixed standard. States adopt it through their own bulletins; roughly half had adopted it as of early 2025.
What it covers
The NAIC Model Bulletin sets out regulatory expectations for insurers' use of artificial intelligence systems. It expects each insurer to develop, implement, and maintain a written AI Systems (AIS) Program designed to ensure decisions made or supported by AI systems comply with applicable insurance laws, including those prohibiting unfair trade practices and unfair discrimination.
The expected program addresses governance, risk management controls, and internal audit functions, and extends to AI systems and predictive models developed or deployed by third-party vendors. The bulletin is principle-based and does not prescribe specific technical standards; regulators evaluate whether an insurer's program is reasonable given the insurer's use of AI and the risk of consumer harm. States implement the bulletin by issuing their own substantially similar bulletins.
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