NAIC AI Evaluation Tool Targets Fall 2026 Adoption
The National Association of Insurance Commissioners expects to adopt the AI Systems Evaluation Tool at the 2026 Fall National Meeting, according to the NAIC’s artificial intelligence topic page. The tool, which has been running as a 12-state pilot since March 2026, is designed to give state examiners a common framework for assessing how insurers govern AI systems.
The timing matters. If the tool is adopted in the fall, it becomes part of the examiner toolkit for 2027 market conduct and financial condition exams. Carriers that have been treating AI governance as a forward-looking project will face questions about their inventory, risk assessment, high-risk system documentation, and data lineage. The carriers that have prepared will have those answers ready. The carriers that have not will be trying to build them under exam pressure.
The tool’s four-exhibit structure is already public. Exhibit A asks for a quantitative inventory of AI systems. Exhibit B asks for a governance risk assessment. Exhibit C focuses on high-risk systems. Exhibit D asks for data source and lineage details. The pilot is testing whether those questions produce useful evidence and whether carriers can answer them with documents they already have. The feedback from pilot states will shape the final version, but the core structure is unlikely to change dramatically.
Fall adoption does not mean every state will use the tool immediately. State adoption of NAIC instruments is uneven, and some states may take time to integrate the tool into their examination processes. However, the largest states and the most active market-conduct regulators tend to follow NAIC guidance quickly. Carriers operating in multiple states should assume that at least a subset of regulators will begin using the tool in 2027, and that others will use it as a benchmark even if they do not formally adopt it.
The practical work for carriers between now and the fall meeting is to pressure-test their own documentation against the four exhibits. A good test is to ask whether a regulator could walk from Exhibit A to Exhibit D in your company without finding contradictions. If the inventory says a system is low-risk but the governance committee spent three meetings on it, the mismatch is a problem. If the data lineage for a high-risk model does not match the model documentation, the examiner will notice.
Carriers should also use the summer to update their AI governance training. Examiners using the tool will ask questions of business-line owners, not just compliance officers. If the person who runs the claims system cannot explain how the AI within it is monitored, the answer will be more damaging than a missing document. The best-prepared carriers are running tabletop exercises with the four exhibits now, so that the people who own the systems can answer examiner questions directly. They are also identifying which business owners can speak to each system and ensuring those owners have the documentation to back up their answers.
We track the working group’s materials weekly. For the full breakdown of what each exhibit asks, see our guide to the NAIC AI Evaluation Tool.