Governed underwriting, pricing, claims, and reserving.

AI governance and compliance for insurance: the regulatory perimeter inside which AI-driven underwriting, pricing, and claims decisions now operate, and the per-decision evidence regulators ask for.

  • 01AI-driven underwriting, rating, claims handling, and reserving sit inside the NAIC Model Bulletin on the Use of AI by Insurers (adopted or proposed in 20+ US states), Colorado Regulation 10-1-1 (the first state-level algorithmic accountability rule in insurance, in force 14 Nov 2023), NY DFS Circular Letter No. 7, and Connecticut Bulletin MC-25. State DOIs now ask for evidence of unfair-discrimination testing, governance, and lifecycle documentation on examination.
  • 02Solvency II 2026 Review Amendments (in force from Jan 2026, national transposition 30 Jan 2027) tightens governance of internal models and ORSA, including model-change notification and independent validation evidence. The Bermuda BMA Statement of Principles on AI in (Re)Insurance carries the same expectations into every cedant relationship for the largest reinsurance domicile globally.
  • 03The IAIS Application Paper on the Supervision of AI sets supervisory expectations across 175+ member jurisdictions on governance, accountability, fairness, robustness, transparency, and explainability. EU AI Act Article 9 (deferred under Digital Omnibus on AI to 2 Dec 2027 standalone, 2 Aug 2028 embedded) applies to insurance pricing, claims, and underwriting systems as high-risk AI.
  • 04DORA (Digital Operational Resilience Act, in force 17 Jan 2025) requires financial entities including insurers and reinsurers to maintain an ICT risk management framework, conduct resilience testing, and govern third-party providers (including AI vendors) with mandatory incident reporting. IFRS 17 requires reserving models to produce evidence compatible with the current-measurement disclosure schedule.
  • 05The per-decision audit record satisfies all of the above on one chain: governed-decline rate, MTBF, availability, an A-to-F risk grade, the model-validation trail, and a cryptographically chained history. Exports natively to the NAIC Annual Statement, the Solvency II SFCR, and the AM Best BCAR. The evidence sits on the regulator's desk before the exam starts.

The insurance regulatory surface, by the calendar.

Every framework below is enforceable today or about to be. Velma evidence is the format both sides expect.

5
11

Open deadlines

5 approaching

Sorted by soonest deadline first.

0days to enforcement
Jan 01, 2026

TRAIGA: Texas Responsible AI Governance Act (HB 149)

AI used in consumer-facing decisions (including insurance underwriting, pricing, and claims) must meet documented governance, impact-assessment, and disclosure obligations enforced by the Texas Attorney General.

Texas joins Colorado as the second comprehensive U.S. state AI law. Penalties are tiered and per-violation.

185days to enforcement
Jan 29, 2027

Insurance Recovery and Resolution Directive (IRRD)

Member states must transpose IRRD into national law. (Re)insurers above defined thresholds must maintain pre-emptive recovery plans, and resolution authorities receive new powers, including write-down and bail-in tools.

Carriers must produce governance and operational evidence for resolvability assessments, including auditable model behavior under stress.

186days to enforcement
Jan 30, 2027

Solvency II: National Transposition Deadline

Member states must transpose the amended Solvency II framework into national law, with the new internal-model governance, ORSA, and validation evidence in force from this date.

Internal-model carriers operating across multiple EU jurisdictions must demonstrate consistent governance evidence to every national supervisor.

492days to enforcement
Dec 02, 2027

EU AI Act: Article 9 (Risk Management)

High-risk AI (including insurance pricing, claims, and underwriting systems) must ship with documented risk management, human oversight, and regulator-readable audit trails.

Original 2 Aug 2026 deadline deferred by the Digital Omnibus on AI provisional agreement (May 2026). Standalone systems now in force 2 Dec 2027; embedded systems 2 Aug 2028. Fines up to 7% of global turnover. The deferral confirms the audit-format gap; it does not eliminate it.

736days to enforcement
Aug 02, 2028

EU AI Act: Article 6 Phase 3 (Embedded High-Risk)

Full conformity obligations for high-risk AI in embedded products (including those covered by sector-specific safety legislation) take effect.

Original 2 Aug 2027 deadline deferred to 2 Aug 2028 by the Digital Omnibus on AI provisional agreement. Captures the long tail of embedded AI in financial-services infrastructure.

Already in force

11 examinable

The examiner can cite any of these on first request.

178days examinable
Jan 30, 2026

Solvency II: 2026 Review Amendments

Amended framework tightens governance of internal models and ORSA, including model-change notification and independent validation evidence.

Adopted by EU Council. Transposition into national law is now running; internal-model carriers should treat this as live.

268days examinable
Nov 01, 2025

23 NYCRR Part 500: Final Phase Compliance

Final phase of the 2023 amendments (encryption of nonpublic information, asset inventory, and access-control review) must be in place across all NY-licensed financial entities including insurers and CRE lenders.

In force since 2025-11-01, the final phase of the Second Amendment. NY DFS examiners expect operational evidence on first request, with no remediation grace period.

556days examinable
Jan 17, 2025

DORA: Digital Operational Resilience Act

Financial entities, including insurers and reinsurers, must implement an ICT risk management framework, conduct resilience testing, and govern third-party ICT providers, with mandatory incident reporting.

ESAs now have direct supervisory powers over critical ICT providers. Governance evidence is examinable.

608days examinable
Nov 26, 2024

Application Paper on the Supervision of AI

Supervisory expectations across IAIS members for AI governance, accountability, fairness, robustness, transparency, and explainability. Applicable to underwriting, pricing, claims, and reserving.

175+ member jurisdictions. Cross-border insurers face multi-supervisor convergence on AI evidence.

694days examinable
Sep 01, 2024

Statement of Principles: AI Use in (Re)Insurance

Bermuda-domiciled (re)insurers using AI must demonstrate board-level governance, fairness testing, model risk management, and ongoing monitoring, with documentation available on examination.

Bermuda is the largest reinsurance domicile globally. ILS sponsors and reinsurers carry the BMA expectations into every cedant relationship.

746days examinable
Jul 11, 2024

Circular Letter No. 7: AI and External Consumer Data

Insurers using AI or external consumer data sources in underwriting must demonstrate unfair-discrimination testing, governance, and transparency to the regulator.

NY sets precedent for other large-market states. Evidence-grade audit trail is expected.

966days examinable
Dec 04, 2023

Model Bulletin: Use of AI by Insurers

A written AIS program governing the entire lifecycle of AI used in underwriting, rating, claims, and fraud, with board-level oversight and vendor-management evidence.

Adopted or proposed in 20+ U.S. states. State DOIs are now asking for evidence on examination.

986days examinable
Nov 14, 2023

Regulation 10-1-1: Algorithm and Predictive Model Governance

Life insurers using external consumer data or algorithms must maintain a governance framework, test for unfair discrimination, and produce on-demand evidence to the DOI.

First state-level algorithmic accountability rule in insurance. More states are modeling their bulletins on it.

1,278days examinable
Jan 26, 2023

AI Risk Management Framework 1.0

Voluntary framework (Govern, Map, Measure, Manage) referenced by NAIC, federal agencies, and state regulators as the de facto baseline for AI risk evidence.

Treated as the floor of expectation across U.S. financial-services AI examinations.

1,303days examinable
Jan 01, 2023

IFRS 17: Insurance Contracts

Reserve and disclosure framework requiring current-measurement, risk-adjusted, and audit-evidenced insurance contract accounting.

Global standard. Reserving models must produce evidence compatible with the disclosure schedule.

1,571days examinable
Apr 08, 2022

Bulletin MC-25: Use of Big Data and AI

Carriers must document AI governance, vendor controls, and unfair-discrimination testing for consumer-facing models, examined annually.

First U.S. state insurance bulletin specifically targeting big-data and AI; template for other states.

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