NAIC

The National Association of Insurance Commissioners (NAIC) is the U.S. organization through which state insurance regulators develop model laws, model bulletins, and examination tools. It does not have direct enforcement authority over insurers, but its products shape what state insurance departments require.

For insurance AI the NAIC has issued three documents that do different work. The Principles on Artificial Intelligence, adopted in August 2020, address five expectations to “AI actors,” a category that reaches past insurers to rating, data and advisory organizations, and say on their own first page that they do not carry the weight of law. The Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, adopted in December 2023, is a template a state department issues to the insurers it licenses, reminding them that decisions made or supported by AI still have to comply with that state’s unfair trade practices and unfair discrimination laws. The AI Systems Evaluation Tool is the exhibit set a state regulator may work through when an examination reaches a carrier’s AI, and each state decides for itself whether to use it. The Model Bulletin now runs in about half the states; the state tracker records which ones, and on what instrument.

The NAIC also runs committees and working groups, publishes survey results, and coordinates state responses to federal initiatives such as Executive Order 14365. See our guides to the NAIC Model Bulletin and the NAIC AI Evaluation Tool.