Both the NAIC Model Bulletin adopted in December 2023 and the EU AI Act of 2024 impose specific obligations on insurers using AI systems, centering on documentation, human oversight, and the ability to explain decisions. The NAIC Model Bulletin, approved on December 4, 2023, directs insurers to maintain a written Artificial Intelligence Systems program, ensure that AI-driven decisions are accurate and not unfairly discriminatory, and keep documentation that regulators may request at any time. By April 30, 2024, 10 states had adopted related actions. The EU AI Act of 2024 classifies insurance underwriting and claims scoring as high-risk AI applications, requiring logging, accuracy validation, human oversight mechanisms, and transparency measures. Transparency rules take effect in August 2026.
Both frameworks require a document AI system to record what it extracted, from where, with what confidence, and what a human reviewer did with the output. Upstage Studio addresses these demands through exportable audit trails, role-based access controls, and data retention settings, all backed by SOC 2 Type 1, ISO 27001/27701, and HIPAA certifications.