AI Systems (AIS) Program
A written insurance AI governance program that assigns ownership, sets risk appetite, documents testing, and evolves with the company's AI use.
An AI Systems (AIS) Program is the written governance program an insurer builds to oversee its use of artificial intelligence. It is the core deliverable that regulators look for during a market conduct exam. A credible program has named owners, a cross-functional committee that meets regularly, documented policies, and evidence that the program evolved alongside the company’s AI use.
The NAIC Model Bulletin describes the pillars of such a program: governance, risk management, internal controls, and third-party oversight. The AIS Program is where those pillars become operational. It should include risk tiering, testing records, human-review thresholds, vendor monitoring, and escalation paths.
Examiners can usually tell whether a program was built over time or assembled after an exam notice arrived. A strong program includes committee minutes, dated approvals, and a history of model changes. See our guide to AI governance in insurance.