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.
- 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.
- 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.

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