Insurers using AI must now document how their models make decisions.
The NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, adopted in December 2023, requires every insurer using AI to establish a written AIS Program. That program must demonstrate that the insurer can explain the decisions its AI systems make and can produce the underlying documentation when a regulator asks. States are adopting it one by one, and the requirement does not wait for every state to act.
What you are expected to document.
The bulletin's core demand is a defensible, auditable record: the inventory of AI systems in use, the data and logic behind each decision, the bias and discrimination testing performed, and the governance trail showing who approved what and when. In a market-conduct exam, the regulator will not ask for your assurance that the model is fair. They will ask to see the documentation that proves it.
Which states have adopted it.
Illinois, Iowa, Kentucky, and Nevada have adopted the model bulletin, with more states moving in the same direction. Because each adoption can differ, the practical requirement is to track adoption state by state and keep documentation current to the strictest version that applies to your book.
Document the decision, not just the outcome.
Norma maps every AI decision to the frameworks that apply and emits the model documentation, the reasoning, and the audit trail as a single compliance package. That turns the hardest part of the NAIC bulletin, proving the model was explainable, into an artifact you already have.
See how Norma builds the model-documentation trail at norma.northgale.io.