What happened
At the NAIC 2026 Summer National Meeting in Columbus, Ohio, the Big Data and Artificial Intelligence (H) Working Group met on August 13, 2026, to advance two initiatives building on the NAIC's AI Model Bulletin: (1) a 12-state pilot program for an AI Risk Evaluation Supplement requiring insurers to disclose how they use AI systems affecting consumers, with a revised version to be exposed for public comment in early September 2026 and possible adoption at the Fall National Meeting; and (2) development of a new regulatory framework for oversight of third-party data and model vendors used by insurers. NAIC leadership confirmed both initiatives are continuing core priorities in prepared remarks at the meeting.
Why it matters
The NAIC's AI Model Bulletin has already been adopted by a majority of US states as the baseline standard for insurer AI governance; the Risk Evaluation Supplement and third-party vendor oversight framework represent the next layer of binding-in-practice supervisory expectations for how insurers document, disclose, and govern AI systems affecting policyholders (underwriting, claims, pricing). Because NAIC model documents are typically adopted into state law/regulation across most US states, this pilot is a leading indicator of forthcoming state insurance-regulator AI compliance obligations nationally.
Action needed
Insurers participating in the 12-state pilot should prepare to respond to the revised AI Risk Evaluation Supplement exposure draft expected in early September 2026; all insurers using third-party AI/data vendors should monitor the emerging third-party model vendor oversight framework for anticipated new disclosure and due-diligence requirements.