By Lewis Nibbelin, Research Writer, Triple-I
As insurers increasingly turn to AI for opportunities to improve insurance affordability, they must also identify and mitigate the new, complex risks it introduces. A first-of-its-kind State of the Tech Policy Brief, developed by Triple-I’s AI Policy Council, explores how one pilot from the National Association of Insurance Commissioners (NAIC) seeks to establish an AI governance framework that can keep pace with AI and machine learning systems as they evolve.
Launched in March 2026, the NAIC pilot aims to provide regulators standards for assessing how insurers leverage AI without replacing existing market conduct or financial analysis. Such assessment centers around four optional “exhibits:”
- Exhibit A asks insurers to quantify their AI use across business functions;
- Exhibit B evaluates the existing governance structure;
- Exhibit C focuses on the mechanisms behind high-risk AI systems, or those that could impact consumers or financial stability; and
- Exhibit D captures AI data details.
Participating states include California, Colorado, Connecticut, Florida, Iowa, Louisiana, Maryland, Pennsylvania, Rhode Island, Vermont, Virginia, and Wisconsin. Carriers operating in these states can expect documentation requests and should prepare accordingly, such as by maintaining accurate AI inventories, defining human oversight protocols, and verifying models are working as intended.
Involvement in the pilot does not prohibit states from pursuing their own AI regulations, so insurers should continue monitoring legislative changes at the state level as the NAIC’s program remains active through September. Once complete, the program is up for consideration for formal adoption at the NAIC Fall National Meeting in November 2026.
New AI frontier emerges
While current regulatory discussions focus heavily on predictive and generative AI, the technology has already progressed toward another major wave: agentic AI.
Unlike AI tools that depend on human review to function, agentic models can operate independently and execute their own decisions, the brief explains. As such, governance practices must adapt to manage autonomous systems capable of acting without human interaction, raising the regulatory stakes dramatically.
“As insurers evaluate governance frameworks, key considerations include transparency, accountability, regulatory compliance, and consumer trust,” the brief emphasizes. “The approaches insurers develop today will help inform how AI is deployed, monitored, and governed across the insurance value chain going forward.”
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