financial · NAIC Model Bulletin · EU AI Act Annex III · Colorado AI Act
AI Liability Insurance
Annex III 5(c): life/health pricing AI = high-risk — NAIC mirror for US market conduct
—NAIC AI Evaluation Tool vote
Regulatory exposure — commonly overlooked:
The insurer examining you uses AI they cannot govern — Exhibit D applies both directions. · Annex III high-risk list covers 8 domains — one vertical per domain minimum for compliance.
TAM / Exposure
$50B+ US P&C · AI governance exam on insurer AND insured
Insurance lines
AI liability · E&O · D&O
Exhibit authority
EU AI Act Conformity Pack — NAIC Exhibit D — Insurer + Insured Mirror Pack
Global leaders
NAIC · Munich Re · Swiss Re · AmTrust · Counterpart · EU AI Office · EDPB · European Parliament
Dual exam weapon
Same Exhibit A–D feeds market conduct AND financial exams — compounded findings.