AI governance for Oklahoma carriers
The Oklahoma Insurance Department issued Bulletin No. 2024-11 on November 14, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It reminds carriers that any action affecting consumers must comply with Oklahoma law, including the unfair trade practices and unfair claims settlement statutes, regardless of whether AI supported the decision. The bulletin lets a carrier's AIS Program rely in whole or in part on a recognized framework such as the NIST AI Risk Management Framework, and it preserves the Department's authority to examine AI use under the NAIC Market Regulation Handbook.
What Oklahoma expects from your AIS Program
Oklahoma 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
The Oklahoma Insurance Department grounds the bulletin in laws it already enforces:
- Unfair methods of competition and deceptive practices36 O.S. §1204
- Unfair Claims Settlement Practices Act36 O.S. §1250 et seq.
- Corporate Governance Annual Disclosure Act36 O.S. §1534 et seq.
Who it applies to
The bulletin reaches every entity holding a Oklahoma certificate of authority, including:
- Property and casualty carriers
- Life and annuity carriers
- Health carriers and HMOs
- All other entities holding an Oklahoma certificate of authority
State-specific changes: Oklahoma tracks the NAIC model and expressly allows the AIS Program to incorporate a third-party framework such as the NIST AI Risk Management Framework v1.0. The core program expectations match the national framework.
Resources for Oklahoma 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.
Oklahoma AI governance FAQs
What is Oklahoma Bulletin No. 2024-11?
Which companies have to comply in Oklahoma?
Can our AIS Program use the NIST AI Risk Management Framework?
How will Oklahoma enforce it?
How does an Oklahoma carrier get ready?
Sources
- Oklahoma Insurance Department — Bulletin No. 2024-11 (Nov 14, 2024)
- OID press release — AI bulletin (Nov 14, 2024)
- NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
- 36 O.S. §1204 (unfair methods of competition / deceptive practices)
- 36 O.S. §1250.5 (Unfair Claims Settlement Practices Act)
- 36 O.S. §1534 et seq. (Corporate Governance Annual Disclosure Act)
Get audit-ready for Oklahoma Bulletin 2024-11
Swept AI supervises your models and produces the AIS Program evidence Oklahoma examiners can request.