NAIC Launches AI Evaluation Tool, Advances Cybersecurity and Privacy Initiatives for Insurers

April 18, 2026
NAIC Launches AI Evaluation Tool, Advances Cybersecurity and Privacy Initiatives for Insurers
  • The Big Data and Artificial Intelligence (H) Working Group is moving to operationalize the NAIC Model Bulletin on AI and piloting an AI System Evaluation Tool with 12 regulators and a diverse mix of insurers, running March through September 2026, with updates and refinements planned for the Fall 2026 meeting.

  • TPDM Group narrowed its consumer-impact focus to pricing and underwriting while planning iterative expansion and continuing oversight of registry development and governance standards.

  • Looking ahead, alignment with a federal AI framework is prioritized, including child protection, community safeguards, IP, and innovation, plus scrutiny of AI-enabled claim handling for transparency and bias risk.

  • CyberCube presented rising ransomware threats and the way generative AI could enhance attacker capabilities, underscoring resilience needs and potential new AI-related coverage considerations for cyber (re)insurers.

  • A four-tier AI risk taxonomy (unacceptable, high, medium, low) was proposed to guide regulator focus and risk assessment, along with a Compliance Report structure for insurers to demonstrate Model Bulletin compliance.

  • The Third-Party Data and Models (H) Working Group explored revisions to the Risk-Based Regulatory Framework, proposing a centralized NAIC registry for third-party data and model vendors to standardize governance and consumer protection, with ongoing questions on mandatory versus voluntary registration, framework versus model law, and scope beyond pricing and underwriting.

  • The 2023-adopted Model Bulletin aims to standardize regulator expectations on AI governance, data handling, model cards, drift testing, and bias testing to shield consumers from AI-driven harms.

  • The Cybersecurity (H) Working Group adopted its recent meeting minutes and advanced the Cybersecurity Event Notification Portal to centralize state-level cyber-event reporting as part of implementing Insurance Data Security Model Law #668.

  • AI governance trends highlighted cross-functional governance, vendor transparency, scoped use-case reviews, lifecycle risk management, potential burdens on smaller firms, and the need for ongoing training to prevent skill atrophy.

  • SupTech/GovTech Subgroup and Data Call Study Group report progress building state data analytics capabilities, including a regulator access pilot to high-quality data and a data elements inventory for market regulation data like MCAS and complaints, with ad hoc data calls and educational opportunities planned for 2026.

  • Privacy Protections (H) Working Group progress on Model 672 revisions with a public draft expected by late 2026 after feedback on Articles VI and VII.

  • The US NAIC Innovation, Cybersecurity, and Technology (H) Committee met in spring 2026 in San Diego to review and adopt reports from its working groups and subgroups.

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