AI governance for Hawaii insurers
The Hawaii Insurance Division issued Commissioner's Memorandum 2025-13A on December 10, 2025, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It reminds insurers that any decision touching consumers must comply with Hawaii insurance law, including the laws on unfair trade practices and unfair discrimination, regardless of whether an AI system supported the decision. The memorandum expects every authorized insurer to maintain a written AIS Program sized to the potential harm a model could cause, and it recognizes the NAIC's 2020 Principles on Artificial Intelligence as an appropriate source of guidance. It reaches the full insurance life cycle, from product development through claims and fraud detection.
What Hawaii expects from your AIS Program
Hawaii adopted the NAIC model verbatim, so the program expectations match the national framework.
Governance
A written program with clear ownership. Senior management is accountable to the board, and a cross-functional body oversees AI across its whole life cycle.
Risk Management & Internal Controls
Controls at every stage of the model life cycle, from data sourcing through retirement, sized to the potential harm to consumers.
Third-Party AI Systems & Data
The insurer stays responsible for AI it did not build. Vendor relationships need diligence, contract rights, and the ability to produce evidence.
Documentation & Audit-Readiness
Section 4 spells out what an examiner can ask for. Treating that list as a standing requirement is what keeps a program defensible.
Legal authority
The Hawaii Insurance Division grounds the bulletin in laws it already enforces:
- Unfair Methods of Competition and Unfair and Deceptive Acts and PracticesHaw. Rev. Stat. ch. 431, art. 13, pt. I (HRS §431:13-103)
- Property and casualty rate regulationHaw. Rev. Stat. ch. 431, art. 14
- Corporate Governance Annual DisclosureHaw. Rev. Stat. ch. 431, art. 3G
- Market ConductHaw. Rev. Stat. ch. 431, art. 2D
Who it applies to
The bulletin reaches every entity holding a Hawaii certificate of authority, including:
- Property and casualty insurers
- Life and annuity insurers
- Health insurers and HMOs
- All authorized insurers offering policies in Hawaii
State-specific changes: Hawaii tracks the NAIC model and, consistent with that model, lets an insurer's AIS Program rely in whole or in part on a recognized framework such as the NIST AI Risk Management Framework v1.0. The core program expectations match the national framework.
Resources for Hawaii insurers
Start with these plain-language explainers and field guides.
What is the NAIC Model Bulletin on AI?
The NAIC Model Bulletin on the Use of AI Systems by Insurers is the template most states use to set AI governance expectations. Here is what it says and why it matters.
GuideWhat is an AIS Program?
An AI Systems Program (AIS Program) is the written program the NAIC Model Bulletin expects every insurer to maintain. Here are its four pillars and what each one requires.
GuideWhat are the NAIC AI Principles?
The NAIC AI Principles, adopted in 2020, are the foundation beneath every state AI bulletin. The five principles spell FACTS: Fair, Accountable, Compliant, Transparent, and Secure.
GuideAI in Insurance: Key Regulatory Definitions
The NAIC Model Bulletin defines the terms that carry legal weight, from AI System to Adverse Consumer Outcome to Model Drift. Here is what each one means for insurers.
ArticleInsurance Regulators Are Forcing AI Governance. Most Carriers Aren't Ready.
State insurance regulators and bar associations are sounding the alarm on AI in insurance. Legal and regulatory pressure is forcing insurers to operationalize AI governance, not just document it.
ArticleThe NAIC Bulletin Is the Floor Your Reinsurer Will Hold You To
Twenty-four jurisdictions have adopted the NAIC Model Bulletin on AI. Most carrier compliance teams are working to the regulatory text. Their reinsurers will use the same document as an evidentiary baseline at the next placement, and the cedent that meets the floor and stops there is preparing for the wrong audience.
Hawaii AI governance FAQs
What is Hawaii Commissioner's Memorandum 2025-13A?
Which companies have to comply in Hawaii?
Can our AIS Program use the NIST AI Risk Management Framework?
How will Hawaii enforce it?
How does a Hawaii insurer get ready?
Sources
- Hawaii Insurance Division: Commissioner's Memorandum 2025-13A (December 10, 2025)
- Hawaii DCCA: Commissioner's Memorandum 2025-13A page
- NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
- Haw. Rev. Stat. ch. 431 (Insurance Code, incl. art. 13, 14, 3G, 2D)
- HRS §431:13-103 (unfair methods of competition and deceptive practices)
Get audit-ready for Hawaii Memorandum 2025-13A
Swept AI supervises your models and produces the AIS Program evidence Hawaii examiners can request.