Where does the regulatory framework really stand
The National Association of Insurance Commissioners (NAIC) adopted a model bulletin on the use of artificial intelligence systems by insurers in December 2023, and about half of the states have since adopted it or issued comparable guidance. It is the most visible reference point for AI governance in the insurance sector and, by design, is a process document: it requires carriers to maintain a written AI governance program covering board accountability, risk management, and third-party vendor oversight, but it does not specify testing methodologies, mandate outcome data collection, or direct carriers on what to do when a deployed model produces evidence of disproportionate impact.
