The NAIC Is Building an AI Evaluation Playbook. Claims Leaders Should Know What It Will Ask.
In March, insurance regulators in 12 states began piloting a new way to examine insurers’ use of artificial intelligence. The National Association of Insurance Commissioners is testing whether its AI Systems Evaluation Tool can help insurers explain how they govern AI and help regulators understand how the technology is being used.
The next public checkpoint arrives soon. The Big Data and Artificial Intelligence Working Group is scheduled to meet Aug 13, 2026 during the 2026 Summer National Meeting. Materials posted for the working group’s latest public meeting show company surveys continuing through Sep 30, 2026, Tool 5.0 expected to enter a 30-day comment period in September, and a later version potentially reaching the NAIC for adoption consideration in November.
As the CEO of an AI company serving insurance carriers, I am watching this process closely. The industry has been given a preview of the questions regulators may ask in the future, and carriers and vendors should understand what those questions reveal.
This is a preview, not a pass-fail test
Tool 4.0 contains four exhibits. Exhibit A inventories AI systems by operational area. Exhibit B examines the insurer’s governance and risk-management framework. Exhibit C requests details about systems the carrier considers high-risk. Exhibit D asks about the types and sources of data involved.
The structure is intentionally proportional. According to the pilot summary, participating states are expected to spend more time on systems that could create serious consumer or financial consequences and less time on low-risk back-office tools. States can also tailor the questions to particular companies and examinations.
That matters because “AI” is not a useful risk category by itself.
A system that prices a policy, automatically determines eligibility, or initiates a payment does not perform the same work as a system that organizes documents or drafts correspondence. The models, data, authority, possible harm, and appropriate controls are different. A useful evaluation needs to recognize those differences.
NAIC’s tool distinguishes systems that support a person, augment a decision, or automate a process. But in a real claims workflow, one system may perform more than one of those functions. The carrier will need to explain the use case with more precision than a product label provides.
This is one reason the pilot is worth following. The July working-group materials identify definitions, materiality, and the sometimes interchangeable use of “model” and “system” as areas that may need additional clarity. Those are practical questions, not abstract policy debates.
A bounded claims tool should be straightforward to explain
At Voltaire, our use case is specific. We help P&C claims organizations complete policy-supported correspondence faster. An adjuster supplies the claim context, including the items and reasons associated with the carrier’s position. Voltaire helps retrieve and assemble policy language, construct the correspondence, and format a draft for the carrier. Along with a comprehensive QA suite for all letters adjusters produce.
Voltaire does not underwrite policies, set rates, issue claim payments, or determine coverage. It automates high-touch compliance work around a decision made within the carrier’s claims operation.
That distinction is important when reading Tool 4.0.
An insurer using Voltaire would likely identify the use case under Claims/Adjudication in Exhibit A. The insurer would determine whether its particular deployment has direct consumer impact and whether the system is best described as support, augmentation, automation, or some combination at different stages.
The drafting step is automated. The underlying coverage position is not. The output may ultimately be sent to a consumer, but it first moves through the carrier’s established review and approval process.
This is the kind of bounded role that a carrier should be able to document clearly. The system has a defined job, identifiable inputs, a visible output, and measurable operating results. Its place in the workflow does not have to be inferred from a broad promise that AI will “transform claims.”
What passing with flying colors actually means
The NAIC tool does not award a passing grade. For a carrier and its vendor, passing with flying colors would mean being able to respond to the inquiry without scrambling to reconstruct how the system works.
The carrier should be able to produce a coherent record of:
- The system’s intended use and explicit limits
- The model or system name, vendor, version, and implementation date
- Whether it supports, augments, or automates each relevant workflow step
- The data types and sources involved
- Pre-deployment validation and ongoing testing
- Monitoring, change management, and escalation procedures
- Employee training and operating guidance
- Evidence that the system continues to perform its assigned task
Claims correspondence is particularly well suited to this kind of evaluation because the work produces a reviewable artifact.
A carrier can preserve the claim information supplied to the system, the policy documents available to it, the generated draft, reviewer changes, and the final letter. It can connect that evidence to operational measures such as:
- Time required to complete the letter
- Fidelity of reproduced policy language
- Unsupported or omitted content
- QA pass rates
- Frequency and substance of reviewer corrections
- Rework and escalation rates
- Performance after model or configuration changes
- Behavior when the necessary information is missing or ambiguous
These measures answer two questions at once. They show whether the controls are working, and they show whether the technology is creating the value the carrier purchased it to create.
For Voltaire, that means demonstrating how AI claims letter software can deliver faster letter completion, consistent policy-language assembly and formatting, and less review drag. It also means documenting limitations, testing, monitoring, data handling, and changes in a form the carrier can use.
That is a stronger position than relying on a generic statement about responsible AI. A narrow, observable system can be evaluated against the work it performs.
Vendor readiness should reduce implementation drag
The third-party questions in the NAIC materials deserve attention because most carriers will not build every AI capability internally.
The NAIC’s Model Bulletin on the Use of AI Systems by Insurers says an insurer’s AI program should address third-party systems. It discusses vendor due diligence, testing, documentation, audit rights, regulatory cooperation, data practices, and ongoing monitoring. Tool 4.0 follows the same basic logic.
The regulated insurer remains responsible for explaining its use of the technology. A vendor that can supply clear documentation makes that easier. A vendor that cannot may create work for procurement, compliance, legal, information security, claims leadership, and eventually an examination team.
This does not have to turn every implementation into a year-long governance project. The opposite should be true.
When a product has a clear use case, defined boundaries, testable output, established implementation process, and usable vendor documentation, the carrier should be able to assess it faster. Readiness can reduce repetitive diligence, shorten internal review, and help the claims organization reach operating value sooner.
That is how Voltaire should fit into this conversation. Not as a regulatory product or a tool that interprets the NAIC framework for carriers, but as a claims application whose purpose, workflow, performance, and limits can be explained.
What we are watching next
The pilot still has meaningful questions to resolve.
How will states distinguish a model from a larger AI system? How consistently will they define materiality and high risk? How will a system be classified when it automates one task but only supports another? How much variation will carriers face when states tailor the exhibits? What evidence will regulators expect from third-party vendors?
The Aug 13, 2026 working-group meeting should provide another indication of where the pilot is heading. Tool 5.0 and its anticipated September comment period will matter even more because they will show how the NAIC translates the pilot’s early experience into revisions.
We will be watching those developments and assessing what they mean for claims technology and carrier implementations. There will be time for a follow-up once the next version is public.
For now, the practical message is simpler. Carriers should know where AI is being used, what job each system performs, what information it touches, how its output is tested, and what evidence the vendor can provide.
That is not a call for more regulation. It is a recognition that the evaluation questions are taking shape, and that well-built, well-documented claims tools should be prepared to answer them while continuing to deliver what carriers need: faster claim-letter completion, more consistent correspondence, and less manual drafting and review work.