AI governance for Michigan carriers
Michigan's Department of Insurance and Financial Services issued Bulletin 2024-20-INS on August 7, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. DIFS applied the model with no Michigan-specific changes, so the AIS Program expectations match the national framework. The bulletin reaches every entity holding a Michigan certificate of authority, including health plans and HMOs, and DIFS has signaled it will request AIS Program documentation during investigations and market conduct exams.
What Michigan expects from your AIS Program
Michigan 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 carrier 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
Michigan DIFS grounds the bulletin in laws it already enforces:
- Unfair and Prohibited Trade Practices and Frauds ActMCL 500.2001 et seq.
- Corporate Governance Annual Disclosure ActMCL 500.1751 et seq.
- Property and casualty rating standardsMCL 500.2403
Who it applies to
The bulletin reaches every entity holding a Michigan certificate of authority, including:
- Carriers
- Nonprofit health service plans
- Health maintenance organizations (HMOs)
- Dental plan organizations
State-specific changes: None. Michigan adopted the NAIC model bulletin verbatim, with no state-specific modifications to the definitions or program expectations.
Resources for Michigan carriers
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 carrier 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 carriers.
ArticleAI Governance for Insurance Carriers: Where AI Runs Across the Value Chain and What Regulators Expect
Insurance AI governance across underwriting, claims, catastrophe modeling, distribution, and cyber: where AI runs today, how its failures reach the loss ratio, and the evidence state regulators now expect carriers to produce.
ArticleReinsurance AI: How Reinsurers and Rating Agencies Are Underwriting Your AI
Reinsurers and rating agencies are already forming a view of the AI in your rating and claims stack. The treaty clauses, rating methodology, case history, and renewal evidence every carrier should understand.
Michigan AI governance FAQs
What is Michigan Bulletin 2024-20-INS?
Which companies have to comply in Michigan?
Did Michigan change anything from the NAIC model?
How will DIFS enforce the bulletin?
How does a Michigan carrier get ready?
Get audit-ready for DIFS Bulletin 2024-20-INS
Swept AI supervises your models and produces the AIS Program evidence Michigan examiners can request.