Twenty-Six Jurisdictions Want a Written AI Program. Write Down Who Decides.
The NAIC model bulletin asks insurers to govern AI systems that support regulated decisions. Governance that waits is still a wait.
THE SIGNAL
The National Association of Insurance Commissioners adopted its Model Bulletin on the Use of Artificial Intelligence Systems by Insurers on December 4, 2023. The bulletin addresses inaccurate outputs, unfair bias and data vulnerabilities, and it expects insurers to maintain a written program for the responsible use of AI systems that make or support regulated decisions.
The NAIC’s adoption map dated August 31, 2026 lists 25 states plus the District of Columbia. The most recent adopter on that list is Mississippi, through Bulletin 2026-9 on July 22, 2026.
BEFORE
Hypothetical: a property and casualty carrier’s claims triage model flags a water damage claim for special investigation. The adjuster sees no fraud indicators and wants to clear the flag. Clearing it requires sign-off from the claims manager who chairs the weekly exceptions review.
The policyholder waits for next Thursday. The file is ready. The person who can release it is not.
WHAT THE WAIT COSTS
The customer waits, a complaint becomes more likely, and the adjuster spends the week answering calls instead of closing files. When an examiner asks how model overrides are governed, the honest answer is a meeting calendar.
AFTER
The written program names who can override what. The adjuster’s override arrives with the model’s reason codes and the adjuster’s evidence attached.
The claims manager approves from the packet the same day. Every override lands in a log that feeds the program’s monitoring, so the program learns from the decisions people actually make.
HOW WISDOMTWIN FITS
WisdomTwin.ai is building a sovereign judgment layer for regulated enterprises in banking, healthcare, legal, government, pharma and defense. It is designed to run inside your own environment, assemble the decision packet with the evidence attached, route it to the named person who holds the authority, and keep a record of who released the decision and why.
We don’t replace judgment. We remove the wait.
TRY THIS THIS WEEK
Check your state’s status on the NAIC adoption map.
List the AI-supported decisions in claims, underwriting and pricing that need a human override path.
For each one, name the approver and the longest a policyholder should wait.
SOURCES
NAIC, NAIC Members Approve Model Bulletin on Use of AI by Insurers, December 4, 2023: https://content.naic.org/article/naic-members-approve-model-bulletin-use-ai-insurers
NAIC, Implementation of NAIC Model Bulletin: Use of Artificial Intelligence Systems by Insurers (status as of August 31, 2026): https://content.naic.org/sites/default/files/legal-adoption-map-ai-model-bulletin.pdf
Examples in this issue are hypothetical, and nothing here describes a customer result.
Book a 20-minute call: https://calendly.com/romanbodnarchuk/20min
Roman Bodnarchuk, Co-Founder and CEO, WisdomTwin.ai