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
—CPRA automated decision-making + AB 5 spillover
Regulatory exposure — commonly overlooked:
The insurer examining you uses AI they cannot govern — Exhibit D applies both directions. · CPRA ADM opt-out requires proof of what automated system decided — receipt is opt-out infrastructure.
TAM / Exposure
$50B+ US P&C · AI governance exam on insurer AND insured
Insurance lines
AI liability · E&O · D&O
Exhibit authority
California CPRA ADM Pack — NAIC Exhibit D — Insurer + Insured Mirror Pack
Global leaders
NAIC · Munich Re · Swiss Re · AmTrust · Counterpart · CPPA · CA AG · Silicon Valley insurers
Dual exam weapon
Same Exhibit A–D feeds market conduct AND financial exams — compounded findings.