NAIC Model Bulletin
The NAIC's non-binding guidance for state insurance regulators on how insurers should govern, document, and test their use of AI systems.
The NAIC Model Bulletin on the Use of AI Systems by Insurers is the closest thing U.S. insurance has to a national AI governance standard. It was adopted by the NAIC in December 2023 and recommended to the states for adoption, with or without modification.
The Bulletin sets expectations in four areas:
- Governance: insurers must have a governance framework that covers AI risk, accountability, and board or senior-management oversight.
- Risk management: insurers must identify and assess risks of adverse outcomes, including unfair discrimination, from AI systems used in insurance practices.
- Development and use: insurers must document AI systems across the lifecycle, including third-party-developed systems.
- Third-party AI: insurers must manage AI developed or deployed by vendors, including contractual controls and oversight.
It is not a model law or regulation, so it does not create enforceable obligations on its own. State adoption determines whether any part of it becomes binding. Some states adopt the Bulletin as guidance only; others fold it into bulletins, regulations, or examination procedures. See our guide to the NAIC Model Bulletin and how it fits into AI governance in insurance.