Exhibit C
The AI-acquisition-and-use section of the NAIC AI Evaluation Tool, covering development practices, generative AI, and third-party systems.
Exhibit C of the NAIC AI Evaluation Tool covers the acquisition, development, and use of AI systems. It applies both to systems built internally and to systems acquired from a third party.
The exhibit is concerned with:
- System requirements and design documentation.
- Validation and testing before deployment.
- Monitoring and change management after deployment.
- Controls over generative AI and autonomous agentic systems.
Because many insurers use vendor-built AI, Exhibit C often overlaps with vendor oversight. Contractual rights to audit, performance guarantees, and exit provisions are common evidence items. See our NAIC AI Evaluation Tool guide for the complete checklist.