NAIC AI Systems Evaluation Tool — 12-State Market Conduct Pilot Program (2026)
United States · NAIC Big Data and AI (H) Working Group — AI Systems Evaluation Tool Pilot (launched March 2, 2026)
The National Association of Insurance Commissioners launched a 12-state pilot program in March 2026 to test a new 'AI Systems Evaluation Tool' — a standardized framework giving insurance examiners a structured method to assess how insurance companies govern their AI systems during market conduct and financial examinations. The 12 participating states are California, Colorado, Connecticut, Florida, Iowa, Louisiana, Maryland, Pennsylvania, Rhode Island, Vermont, Virginia, and Wisconsin. The tool requires insurers to complete four exhibits: one quantifying AI usage, one assessing governance risk, one detailing high-risk AI systems, and one documenting AI data practices. The pilot runs through September 2026, with tool updates through October 2026 and formal NAIC adoption expected at the Fall National Meeting in November 2026.
Technical detail
NAIC Big Data and Artificial Intelligence (H) Working Group — AI Systems Evaluation Tool (AISET) Pilot Program. Launched March 2, 2026. Participating jurisdictions (12): California, Colorado, Connecticut, Florida, Iowa, Louisiana, Maryland, Pennsylvania, Rhode Island, Vermont, Virginia, and Wisconsin. Tool structure: Exhibit A (quantify insurer AI system usage), Exhibit B (AI governance risk assessment framework), Exhibit C (high-risk AI system detail), Exhibit D (AI data details). Pilot scope: each state independently determines which carriers to examine and how to integrate the tool into market conduct reviews, financial analysis, or financial exams; pilot tests across property/casualty, life, and health lines. Monthly coordination calls among participating states. Pilot timeline: March–September 2026 → October 2026 revision and re-exposure for public comment → November 2026 Fall National Meeting adoption vote. Post-adoption, states would embed AISET into existing exam practices; examiners would send requests to insurers requiring completion of the four exhibits. Distinct from the NAIC AI Model Bulletin (adopted by 25+ states as of 2026): the Bulletin establishes governance expectations; the AISET is the examination instrument that operationalizes them. Status set to 'proposed' because the tool is in pilot and not yet formally adopted as NAIC guidance.
Who is protected: Policyholders and consumers in the 12 participating states and (after adoption) all states — the tool ensures regulators can meaningfully examine insurer AI governance programs
Who must comply: Insurers examined by any of the 12 pilot states (or all NAIC-member states after formal adoption) that use AI systems in insurance operations
Key facts
| Jurisdiction | United States |
|---|---|
| Level | Federal |
| Status | Proposed / pending |
| Protection strength | Limited protection |
| Effective date | 2026-03-02 |
| Enacted | 2026-03-02 |
| Citation | NAIC Big Data and AI (H) Working Group — AI Systems Evaluation Tool Pilot (launched March 2, 2026) |
| Enforced by | State insurance departments in the 12 participating states (and potentially all NAIC-member states after formal adoption); NAIC Big Data and Artificial Intelligence (H) Working Group coordinates |
| Private right of action | No — agency enforcement only |
| Penalties | Tool itself has no independent penalty authority; findings feed into standard market-conduct examination process with existing enforcement powers |
| Topics | insurance AI · automated decision-making · AI disclosure and transparency · consumer protection |
| Last verified | 2026-07-12 |
| Official source | NAIC AI Systems Evaluation Tool Pilot — Pilot Project Summary (NAIC official PDF) ↗ |
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- FTC Act Section 5 (unfair/deceptive AI) · In effect
- TAKE IT DOWN Act · In effect
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Related insurance AI rules elsewhere
- Colorado AI Act (repealed) · Repealed / replaced
- SB 26-189 (Colorado ADMT Law) · Enacted (not yet in effect)
- SB 444 (GA AI Insurance Review) · Enacted (not yet in effect)
- SB 1120 (CA Physicians Make Decisions Act) · In effect
- TX SB 815 (No AI-Only Insurance Denials) · In effect
- CO Insurance Algorithmic Discrimination Law · In effect
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