AI Compliance Checklist - Insurance Edition

Overview

Insurance AI compliance presents unique challenges that generic AI governance frameworks don't address. The industry's state-by-state regulatory structure means a single AI model used for underwriting or claims may need to comply with 50+ different regulatory regimes simultaneously.

This comprehensive compliance checklist is built specifically for insurance companies deploying AI in underwriting, pricing, claims, and customer service. It addresses the NAIC Model Bulletin requirements, state-specific laws in high-scrutiny jurisdictions, actuarial professional standards, and the practical realities of rate filing and market conduct examinations.

The toolkit recognizes that insurance AI compliance isn't just about technology governance—it's about demonstrating actuarial justification, preventing unfair discrimination, and maintaining the trust compact between insurers and policyholders.

What's Inside

• NAIC AI Principles Checklist: Fair and ethical, accountable, compliant, transparent, secure/robust requirements with specific compliance actions
• State-Specific Requirements: Detailed checklists for California (Prop 103, AB 1950), New York (DFS Circular Letter), Colorado (SB 21-169), Illinois (HB 3445), Massachusetts, Texas, and Florida
• Multi-State Compliance Matrix: At-a-glance view of rate filing requirements, AI guidance, discrimination testing, and policyholder rights by state
• Actuarial Standards Compliance: ASOP 12 (risk classification), ASOP 23 (data quality), ASOP 25 (credibility), ASOP 41 (communications), ASOP 56 (modeling)
• Rate Filing Documentation: AI-specific actuarial memorandum requirements, variable justification templates, and common regulator questions with prepared answers
• Unfair Discrimination Testing: Disparate impact analysis protocols, proxy variable screening, and protected class testing requirements
• Market Conduct Exam Readiness: Documentation checklist, common findings to avoid, and remediation planning
• Policyholder Transparency Templates: Adverse decision notices, AI disclosure language, and appeal process documentation
• Vendor Due Diligence: Assessment checklist for third-party AI (ISO, Verisk) including model governance and discrimination testing requirements
• 90-Day Implementation Roadmap: Insurance-specific timeline with month-by-month deliverables

Who This Is For

• Insurance Compliance Officers responsible for regulatory compliance across multiple state jurisdictions
• Chief Actuaries ensuring AI models meet professional standards and rate filing requirements
• Underwriting Leadership implementing AI while maintaining regulatory compliance
• Claims Directors deploying AI in claims processing with appropriate controls
• Insurance Legal Counsel advising on state-specific AI requirements and policyholder rights

Why This Resource

Generic AI compliance frameworks miss the nuances of insurance regulation. This toolkit is built by practitioners who understand that insurance AI compliance requires satisfying both traditional insurance regulators (who care about rates, forms, and market conduct) and emerging AI governance requirements (who care about bias, transparency, and accountability).

Every checklist maps to actual regulatory requirements with specific evidence guidance for market conduct examinations. The state-specific sections reflect current enforcement priorities and examination trends.

FAQ

Q: Which states have specific AI requirements for insurance?

A: California, New York, Colorado, and Illinois have the most developed AI-specific requirements. However, all states' unfair discrimination laws apply to AI, and NAIC guidance is being adopted widely. This toolkit covers requirements across all major jurisdictions.

Q: How does this address actuarial professional standards?

A: The toolkit includes detailed checklists for ASOPs 12, 23, 25, 41, and 56—the key actuarial standards that apply to AI models. Each requirement is mapped to specific compliance actions with documentation guidance.

Q: Can this be used for rate filing preparation?

A: Yes. The toolkit includes AI-specific rate filing documentation requirements, actuarial memorandum guidance, and common regulator questions with suggested responses. It's designed to support successful rate filings for AI-driven pricing.

Q: Does this cover vendor AI like ISO and Verisk models?

A: Yes. The vendor due diligence section specifically addresses third-party AI assessment, including model governance requirements, discrimination testing expectations, and contractual provisions for regulatory compliance.