NAIC Panel on AI Governance and Evaluation Tool
The NAIC’s Big Data and Artificial Intelligence Working Group is scheduled to meet on July 22, 2026, to hear a panel discussion on AI governance trends and receive an update on the AI Systems Evaluation Tool pilot. The meeting is a checkpoint on the path toward the tool’s anticipated adoption at the NAIC Fall 2026 National Meeting, and carriers should pay attention to both the pilot feedback and any signals about how the tool will be used in examinations.
The AI Systems Evaluation Tool is a supplemental examination framework that attaches AI-specific questions to the market conduct, financial condition, and financial analysis handbooks regulators already use. It is organized into four exhibits: Exhibit A inventories AI systems, Exhibit B assesses governance risk, Exhibit C drills into high-risk systems, and Exhibit D asks for data source and lineage details. The pilot, which now includes 12 states, is testing whether the questions are practical for examiners and whether the documentation carriers produce is sufficient.
The July meeting matters because it is the last formal update before the working group finalizes the version for fall adoption. Pilot states have been running the questions against real insurers and real systems, and their feedback could change which documents are treated as sufficient, how high-risk systems are defined, and how examiners interpret governance gaps. Carriers that wait until November to prepare will be reacting to a finished instrument. Carriers that prepare now can close gaps before the exam notice arrives.
The meeting is scheduled for July 22, 2026, at 12:00 PM ET. The agenda includes a panel on AI governance trends and an update on the pilot, which is expected to inform the version presented for adoption at the NAIC Fall 2026 National Meeting. Carriers that cannot attend should still review the materials when they are posted, because the pilot comments often reveal which questions regulators found most difficult to answer and which documentation gaps are most common.
For carriers, the immediate action is to confirm that the inventory and governance documentation they have built for the four exhibits is current and internally consistent. The most common failure point is not a missing policy; it is a disconnect between the systems listed in Exhibit A and the governance oversight described in Exhibit B. If the inventory and the committee do not agree, the examiner will notice. Carriers should also check whether their data lineage documentation for high-risk systems matches the actual data flows, because Exhibit D questions will test that alignment directly.
Carriers should also consider attending the meeting or assigning someone to monitor the transcript, because the panel discussion may offer early signals about how regulators view agentic AI and vendor responsibility. These signals can inform not only NAIC preparation but also responses to state AI legislation and litigation that is already moving through the courts. The transcript is usually published within a few days and is worth reading in full.
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.