Checklist · Insurance

The NAIC AI Systems Evaluation Checklist

Every artifact the NAIC evaluation approach expects an insurer to produce — and how to generate each one continuously instead of annually.

IRIS8 · August 2026 · Reference guide

With the NAIC model bulletin adopted across half the states and an AI Systems Evaluation Tool piloted with state regulators, insurers face a concrete artifact list. Here is the checklist, with the continuous-generation approach for each item.

The written AIS program

Governance structure, accountable owners, risk management process, and internal audit hooks for AI systems. Continuous approach: the program document points at living systems — the inventory, the policy set, the evidence stream — rather than describing intentions.

The system inventory

Every AI system touching underwriting, pricing, claims, fraud, or servicing, with third-party systems included. Continuous approach: gateway discovery keeps the inventory current as a side effect of traffic.

Model cards & documentation

Purpose, data, limitations, and performance per system. Continuous approach: cards assembled from registry metadata and live monitoring rather than written once and aging.

Testing records

Bias and outcome testing appropriate to the system’s use, retained with methodology. Continuous approach: scheduled evaluation runs whose results file into the evidence layer automatically.

Drift & performance monitoring

Evidence that deployed systems are watched, with thresholds and escalation. Continuous approach: behavioral baselines per system, alerts tied to autonomy tier.

Consumer-impact traceability

The ability to explain an adverse or unusual outcome for a specific policyholder. Continuous approach: per-decision reconstruction — the same capability your market conduct exam will eventually ask for by name.

Informational only; not legal advice. Confirm requirements per adopting state.

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