AI governance for Wisconsin insurers
The Office of the Commissioner of Insurance issued its bulletin on the use of AI systems in insurance on March 18, 2025, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers and making Wisconsin the 24th state to do so. It reminds every entity OCI regulates that decisions or actions affecting consumers must comply with Wisconsin insurance law, including the rules on unfair marketing practices and unfair discrimination, whether or not an AI system supported them. The bulletin expects each insurer to maintain a written AIS Program and recognizes the NAIC's 2020 Principles of Artificial Intelligence as an appropriate source of guidance. It lets that program rely on a recognized framework such as the NIST AI Risk Management Framework v1.0, and it preserves OCI's authority to examine AI use under the NAIC Market Regulation Handbook.
What Wisconsin expects from your AIS Program
Wisconsin adopted the NAIC model with some changes. The four pillars below are the shared foundation.
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
Wisconsin OCI grounds the bulletin in laws it already enforces:
- Unfair marketing practicesWis. Stat. § 628.34
- Rate regulationWis. Stat. ch. 625
- Corporate governance annual disclosureWis. Stat. § 610.80
Who it applies to
The bulletin reaches every entity holding a Wisconsin certificate of authority, including:
- Property and casualty insurers
- Life and annuity insurers
- Health insurers and HMOs
- All other entities regulated by OCI
State-specific changes: Wisconsin tracks the NAIC model and expressly allows the AIS Program to adopt, incorporate, or rely on a recognized framework such as the NIST AI Risk Management Framework v1.0. It also substitutes Wisconsin-specific statutory citations, but the core program expectations match the national framework.
Resources for Wisconsin 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.
Wisconsin AI governance FAQs
What is Wisconsin's insurance AI bulletin?
Which companies have to comply in Wisconsin?
Can our AIS Program use the NIST AI Risk Management Framework?
How will Wisconsin enforce it?
How does a Wisconsin insurer get ready?
Get audit-ready for Wisconsin's AI bulletin
Swept AI supervises your models and produces the AIS Program evidence Wisconsin examiners can request.