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Guidance Document IGD-H1Adopted

AI governance for Nebraska insurers

Nebraska's Department of Insurance issued Guidance Document IGD-H1 on June 11, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. The guidance reminds insurers that every decision an AI system touches must still comply with Nebraska insurance law, and it expects each insurer to maintain a written AIS Program. It recognizes the NAIC's 2020 Principles on Artificial Intelligence as an appropriate source of guidance and reaches the full insurance life cycle, from product development through claims.

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GuidanceIGD-H1
IssuedJune 11, 2024
EffectiveUpon issuance
BasisNAIC model bulletin

What Nebraska expects from your AIS Program

Nebraska 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

Nebraska's DOI grounds the bulletin in laws it already enforces:

  • Unfair Insurance Trade Practices ActNeb. Rev. Stat. §44-1521 et seq.
  • Property and Casualty Insurance Rate and Form ActNeb. Rev. Stat. §44-7501 et seq.
  • Corporate Governance Annual Disclosure ActNeb. Rev. Stat. §44-9101 et seq.

Who it applies to

The bulletin reaches every entity holding a Nebraska certificate of authority, including:

  • Property and casualty insurers
  • Life and annuity insurers
  • Health insurers and HMOs
  • All other entities authorized to do business in Nebraska

State-specific changes: Nebraska issued the model as a guidance document (IGD-H1) rather than a numbered bulletin, but the substance tracks the NAIC model. An insurer building to the national framework is building to Nebraska's expectations.

Learn the basics

Resources for Nebraska insurers

Start with these plain-language explainers and field guides.

Guide

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.

Guide

What 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.

Guide

What 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.

Guide

AI 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.

Article

Insurance 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.

Article

The 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.

Nebraska AI governance FAQs

What is Nebraska Guidance Document IGD-H1?
It is the guidance the Nebraska Department of Insurance issued on June 11, 2024 adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It tells insurers that existing Nebraska insurance laws apply to any decision an AI system touches and expects each insurer to maintain a written AIS Program.
Which companies have to comply in Nebraska?
Any insurer authorized to do business in Nebraska, across property and casualty, life, and health lines. The guidance is not limited to a single line of business.
Does the guidance reference the NAIC AI Principles?
Yes. IGD-H1 recognizes the NAIC's 2020 Principles on Artificial Intelligence (fairness and ethics, accountability, compliance, transparency, and secure, safe, and robust systems) as an appropriate source of guidance for building and using AI systems.
How will Nebraska enforce it?
Through existing authority, including the Unfair Insurance Trade Practices Act, the Property and Casualty Insurance Rate and Form Act, and the Corporate Governance Annual Disclosure Act. The Department can request AIS Program documentation during investigations and market conduct examinations.
How does a Nebraska insurer get ready?
Stand up a written AIS Program covering governance, risk management and internal controls, and third-party oversight, then keep model inventories, validation records, and a clear data-to-decision trail examination-ready.
Sources
  1. Nebraska DOI — Guidance Document IGD-H1 (June 11, 2024)
  2. NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
  3. Neb. Rev. Stat. §44-1521 et seq. (Unfair Insurance Trade Practices Act)
  4. Neb. Rev. Stat. §44-7501 et seq. (Property and Casualty Insurance Rate and Form Act)
  5. Neb. Rev. Stat. §44-9101 et seq. (Corporate Governance Annual Disclosure Act)

Get audit-ready for Nebraska's AI guidance

Swept AI supervises your models and produces the AIS Program evidence Nebraska examiners can request.

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