What a Pennsylvania examiner may ask about your AI

A plain-language summary for insurers, from Pennsylvania Insurance Notice 2024-04 and the NAIC's current work. Sources at the end. Checked October 3, 2026.

The rule in one paragraph

In April 2024 the Pennsylvania Insurance Department issued Notice 2024-04, adopting the NAIC Model Bulletin on insurers' use of artificial intelligence systems. It expects an insurer that uses AI to keep a written program governing it: who is accountable, how risks are controlled, and how models and vendor tools are tested and monitored. The Department describes the guidelines as not binding. But it may ask for that program and the documents behind it during an investigation or market conduct action, or "at any time determined necessary by the Insurance Commissioner."

Three questions an examiner may ask

Each is a plain-language version of an item on the documentation list in Section 4 of the Notice.

1. Can you give us your current written AI program, and the documents showing it was adopted?
2. Show us your inventory of the predictive models and AI systems you use to make or support decisions that can result in adverse consumer outcomes.
3. For this vendor's model or data, what due diligence did you do? What do your contracts say about audits and cooperation with regulators, and how have you checked the vendor since?

What is changing now

• Pennsylvania is one of 12 states that piloted the NAIC's AI Systems Evaluation Tool, a set of optional exhibits for regulators, in market conduct exams, financial analysis and financial exams from March to September 2026.
• The NAIC working group is now discussing a draft with the same structure, the AI Risk Evaluation Supplement v5.0 (comment period closed September 29, 2026).
• The draft asks insurers for a model inventory, treats ordinary rating models (GLMs) as machine learning, and asks for each high-risk model's "last date of model testing."
• The pilot plan, written in March, was to consider an updated tool for adoption at the NAIC Fall National Meeting, November 14-17, 2026. That is a plan, not a decision.
• 25 states and the District of Columbia have adopted the NAIC Model Bulletin (NAIC map dated August 31, 2026).

Where bickford fits

Sources

• Pennsylvania Bulletin, 54 Pa.B. 1910 (April 6, 2024), Insurance Notice 2024-04: pacodeandbulletin.gov
• NAIC Model Bulletin: Use of Artificial Intelligence Systems by Insurers (adopted December 2023): naic.org; adoption map, status as of August 31, 2026: naic.org
• NAIC Big Data and Artificial Intelligence (H) Working Group (the v5.0 draft and comment period): naic.org; Pilot Project Summary, March 2, 2026: naic.org

Related

• Pennsylvania Insurance Notice 2024-04: the AI documentation checklist
• The NAIC AI Model Bulletin: what it expects insurers to keep
• What "Not evidenced" means, and why it is scored like a gap
• How to verify an AI decision log