NAIC’s Potential AI Model Law for Insurers: What You Need to Know
On May 12, 2025, the National Association of Insurance Commissioners (NAIC) Big Data and Artificial Intelligence (H) Working Group issued a Request for Information (RFI) that signals a move toward drafting a model law to regulate insurers’ use of artificial intelligence (AI) systems.
This step builds on the NAIC’s previous efforts, including the 2020 Principles on Artificial Intelligence and the 2023 Model Bulletin on the Use of Artificial Intelligence Systems by Insurers. The RFI seeks input from stakeholders about whether uniform statutory requirements should apply nationwide. It also asks how such regulations should address governance, transparency, and accountability around AI.
Key Topics Covered in the RFI
- Should AI-related obligations vary based on insurer size?
- How should third-party AI vendors be regulated?
- Could existing state laws or industry templates serve as regulatory models?
- What governance structures are necessary for AI oversight?
- How to ensure transparency and accountability in AI deployment?
Written comments are due by June 30, 2025. Insurers, AI vendors, and other stakeholders should evaluate whether to submit feedback. Early engagement can influence the shape of a possible model law and help organizations prepare for upcoming requirements.
Why This Matters for Insurers
The RFI underscores the importance of aligning current practices with emerging regulatory expectations. NAIC’s guidance, along with rules from the New York State Department of Financial Services and Colorado’s new legislation on anti-discrimination testing, highlights key compliance areas:
- Documenting AI system use and decisions
- Mitigating risks of discriminatory outcomes
- Preparing for confidential regulatory examinations of AI systems
Insurers currently have a window to adapt their legal and operational frameworks to meet these evolving standards. Proactive measures today can reduce compliance risks tomorrow.
Next Steps
Stakeholders should review the RFI in detail and consider providing formal comments. This is an opportunity to shape rules that could apply across the U.S. and affect how AI is integrated into underwriting, claims, pricing, and other insurance functions.
For professionals looking to deepen their AI knowledge and skills within insurance, exploring specialized AI courses can be valuable. Resources like Complete AI Training’s latest AI courses offer practical insights into AI applications relevant for insurance roles.
Staying informed and prepared will help insurers manage AI risks effectively and maintain compliance as regulatory frameworks develop.
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