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Compliance

NAIC Model Bulletin

AI governance for insurers: documented testing, decision oversight, and incident handling with evidence attached.

At a glance

Who this covers, and who enforces it

Insurers using AI in underwriting, pricing, claims, or marketing, in states that have adopted the NAIC Model Bulletin (adopted December 2023) or substantially similar guidance.

NAIC Model BulletinFramework
Instrument
NAIC Model Bulletin — regulatory guidance
Adopted
December 2023
Reach
A majority of US states by 2026
Enforced by
State insurance departments
Exam trigger
Market conduct examinations

Requirements

What it asks for

  • 1Written AI systems (AIS) governance program
  • 2Oversight of third-party and vendor AI
  • 3Testing for unfair discrimination
  • 4Documentation ready for a market conduct exam

Evidence mapping

What PRISM records against each requirement

Every plan records this evidence as your AI runs. Compliance Reports, which turn it into a reviewed, framework-mapped report, are delivered as a service, on request.

NAIC Model Bulletin
Written AIS program
Projects & Team plus Model Inventory document the program’s scope and ownership.
Vendor AI oversight
Connectors log every third-party AI system feeding data into the environment.
Discrimination testing
Synthetic Scenarios and Evaluators test decision patterns across simulated populations.
Exam-ready documentation
Export & Audit assembles the record an examiner requests.

Primary source

Read the actual text

Everything on this page is drawn from NAIC — Insurance Topics: Artificial Intelligence. The capture is live, not a paraphrase — go straight to the source and check us.

content.naic.org
Capture of NAIC — Insurance Topics: Artificial Intelligence
Live capture, 24 Aug 2026Open the source ↗

Evidence, not certification

This page describes NAIC Model Bulletin’s publicly available requirements and how PRISM’s evidence layer supports them. It is not legal advice, and it does not constitute certification, regulatory approval, or a guarantee of compliance. NAIC Model Bulletin compliance remains your organization’s responsibility, in consultation with qualified counsel.

Ask us about your framework

Tell us how NAIC Model Bulletin applies to your systems and we'll show you the evidence path.