AIS Program
An AIS Program is the written Artificial Intelligence Systems Program that the NAIC Model Bulletin on Use of AI Systems by Insurers expects every insurer to adopt, implement and maintain. The term comes straight from the bulletin, which the NAIC adopted on December 4, 2023 and which more than 24 US states have issued through their own insurance departments.
What the program must cover
The bulletin expects an AIS Program to document five things at a minimum:
- Governance with board or senior management oversight, cross-functional roles across actuarial, data science, underwriting, compliance and legal, and written policies for every stage of the AI lifecycle.
- Risk management and internal controls calibrated to the Degree of Potential Harm to Consumers. Underwriting and claims AI carry tighter controls than back-office assistants.
- Testing and validation that identify errors, bias and unfair discrimination in predictive models and AI systems, with documented remediation when testing fails.
- Third-party vendor oversight including diligence, audit rights in contracts and ongoing monitoring. The insurer stays responsible for vendor AI.
- Documentation and cooperation with regulators, so evidence can be produced quickly during market conduct examinations.
Why it matters
The AIS Program is the artefact a state insurance department will ask for when it examines an insurer's use of AI. The 2026 NAIC AI Systems Evaluation Tool pilot, live in 12 states, tests the program across four exhibits: AI usage, governance framework, high-risk system detail and data source review. An insurer without a documented AIS Program cannot answer the pilot questions or a consumer complaint that leads to a market conduct review.
How VerifyWise covers it
For a clause-by-clause walkthrough of the AIS Program and the controls that satisfy it, see the NAIC AI Principles and Model Bulletin compliance guide.