NAIC AI Evaluation Tool
Optional NAIC exhibits regulators use to ask insurers about their AI systems, renamed the AI Risk Evaluation Supplement in draft 5.0.
The NAIC AI Evaluation Tool, which version 5.0 renames the Artificial Intelligence (AI) Risk Evaluation Supplement, is a set of optional exhibits state insurance regulators can send an insurer to learn how it uses AI systems and whether closer review is warranted. “NAIC AI Evaluation Tool” is shorthand; neither version prints that title.
Twelve states in the pilot work from version 4.0, whose footers read “AI Systems Evaluation Tool.” Version 5.0 remains an unadopted exposure draft. Its written comment period closed on September 29, 2026.
The tool is not a regulation and does not replace exam procedure. It supplements financial analysis, financial examination, and market conduct review procedures, and says existing NAIC resources stay authoritative. Each exhibit asks regulators to trim the request to a limited scope exam. Exhibit B’s AIS Program definition follows the NAIC Model Bulletin, a separate document. That exhibit’s preface says its questions are not meant to create new AIS Program requirements.
The exhibits, in version 5.0 terms:
- Exhibit A counts AI systems and models by operational area, adds a Part Two list for the model inventory, and helps regulators decide whether to go further.
- Exhibit B asks about the AIS Program, in narrative or checklist form.
- Exhibit C details each high-risk AI model in production, under risk criteria the insurer sets.
- Exhibit D sets data categories against the models using them, with internal and third-party source columns.
Our guide to the NAIC AI Evaluation Tool covers each exhibit and the version changes.