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NAIC AI risk supplement pilot adds structured oversight for insurers
The NAIC’s pilot, involving 12 states since March, is set for a revised public exposure cycle in early September, with potential consideration at the Fall National Meeting.
Every seat was taken at the NAIC 2026 Summer National Meeting in Columbus when regulators, insurers, and technology stakeholders met through the Big Data and Artificial Intelligence Working Group to discuss how AI oversight is evolving in the insurance industry. Coverage focused on the NAIC’s AI Risk Evaluation Supplement pilot, which has involved 12 states since March. Participating regulators have met nearly every week, but they have not followed a single uniform process. Some states have incorporated the supplement into planned market conduct or financial examinations, while others have used it as an ad hoc questionnaire, with regulators able to modify or add questions for their needs.
The NAIC plans to expose a revised version for public comment in early September. The published timeline anticipates two exposure periods, additional company feedback, and potential adoption discussion at the Fall National Meeting, while emphasizing that the effort remains a pilot and is not a product certification, rating system, or new insurance law. The group also heard from Edin Imsirovic, Director at AM Best, who discussed governance across predictive, generative, and agentic systems. According to the session coverage, the presentation did not change AM Best criteria, methodology, or rating guidance, and AI is treated within existing AM Best lenses, including innovation and enterprise risk management, to avoid isolating AI as a stand-alone technology risk. The central governance question framed for insurers is whether their AI use is matched by appropriate oversight, rather than simply whether they can describe an impressive AI capability.