AI is no longer a side topic in insurance operations—it’s becoming part of how insurers market, underwrite, price, handle claims, and serve customers. The NAIC’s “Artificial Intelligence” topic page (last updated 1/17/2025) summarizes both how AI is being used and how regulators are responding. For licensing candidates, CE students, and agency/compliance leaders, the practical takeaway is simple: if AI influences a decision or communication, the human and the organization are still accountable for meeting applicable insurance laws and regulations.
What Happened (NAIC signal, in plain language)
The NAIC describes AI as technology that enables computer systems to perform tasks normally associated with human intelligence, including analyzing diverse data (text, images, video, sound) and generating content. The NAIC notes adoption has accelerated due to more available data, greater computing capacity (including cloud computing), and accessible generative AI large language models (LLMs) such as ChatGPT—along with consumer expectations for fast, on-demand service.
In insurance, the NAIC highlights AI’s influence across marketing, pricing, underwriting, claims processing, fraud detection, customer service, and internal efficiency. Examples include 24/7 chatbots and machine-learning models that assess damage severity and predict repair costs using historical data, sensors, and images.
On the regulatory side, the NAIC describes a committee structure monitoring innovation and a dedicated working group that developed AI principles and surveyed insurers on AI/ML usage and governance controls. The NAIC also adopted a Model Bulletin on the Use of Artificial Intelligence by Insurance Companies (December 2023) emphasizing that AI-supported decisions/actions must comply with all applicable insurance laws and regulations. In 2024, the NAIC formed the Third-Party Data and Models (H) Task Force to evaluate and develop a regulatory framework regarding insurers’ use of third-party AI data and models.
Three Plausible Scenarios (Optimistic / Base / Stress)
Scenario 1: Optimistic — “Governed AI becomes routine”
Insurers expand AI use, but governance matures quickly: clear controls, documented oversight, and consistent training. Producers and service teams use AI tools (including chat and content drafting) with defined guardrails and review steps.
Training implication: Licensing and CE programs increasingly reward practical understanding of how AI fits into compliant workflows—especially documentation, communication quality, and escalation when outputs look wrong.
Scenario 2: Base — “Patchwork adoption + steady regulatory expectations”
AI use continues to grow across lines, but controls vary by carrier, vendor, and department. Regulators keep emphasizing that AI doesn’t change legal obligations; organizations need to prove they supervise models and third-party tools appropriately.
Training implication: Teams need repeatable playbooks: what staff can use AI for, what requires human review, and what must be documented. CE becomes the place to standardize these habits across producers.
Scenario 3: Stress — “AI-driven errors trigger scrutiny”
High-visibility issues (e.g., inconsistent decisions, questionable marketing content, or poor customer interactions) drive tighter oversight and faster internal audits. Third-party model risk becomes a focal point, and frontline teams feel the impact through new approval steps and monitoring.
Training implication: The fastest way to reduce operational risk is training discipline: standardized scripts, documentation routines, and escalation triggers when AI outputs conflict with policy, underwriting guidelines, or consumer expectations.
Managers/Compliance Leads: Response by Scenario (policy + process)
This section is designed for agency managers, compliance leads, and training owners who need a workflow—not a whitepaper.
- If Optimistic: codify what “good” looks like. Publish an AI usage standard operating procedure (SOP) for marketing, sales support, and service. Require a short training module and an annual refresher in CE/compliance training.
- If Base: build controls that work across carriers and vendors. Create a single “AI-assisted communication” review rule (e.g., when AI drafts client-facing messages, a licensed person reviews and edits before sending). Track exceptions and coach to patterns.
- If Stress: tighten supervision fast. Implement a temporary enhanced review queue for higher-risk items (replacements, claim complaints, underwriting escalations). Add a third-party tool register so you can answer: “What tools are we using, for what purpose, and who owns oversight?”
Where TSI National fits operationally: use structured training paths (live virtual, in-person, or self-study) to standardize baseline knowledge for new hires (licensing exam prep) and to reinforce compliant behaviors for licensed staff (CE planning and completion). The goal is consistent execution, not one-off reminders.
Student and Producer Guidance: What to Study and Practice Now
AI won’t replace core insurance fundamentals tested on licensing exams or required in CE. But it changes how those fundamentals show up in day-to-day work—especially communication speed and documentation expectations.
- Licensing candidates: keep your focus on exam-weighted fundamentals (policy concepts, ethics, consumer protection themes). Then add a practical layer: practice explaining coverage and exclusions in plain language without relying on AI to “fill gaps.” AI can draft, but you must understand.
- CE students / active producers: prioritize CE that reinforces compliant communication, recordkeeping habits, and process discipline. If your organization uses chatbots or AI-assisted service, ask for the internal rules: what you can delegate to automation and what requires licensed judgment.
- All learners: build a “miss log” not just for practice questions, but for real workflow errors: where an AI draft was unclear, where a chatbot answer needed correction, or where a claim/underwriting interaction required escalation. Review weekly.
90-Day Readiness Plan (measurable actions + owners)
- Days 1–15 (Owner: Compliance lead): inventory AI touchpoints (marketing content generation, chat/customer service, claims intake tools, underwriting triage, third-party data/model usage). Output: a one-page register with tool name, purpose, and accountable owner.
- Days 16–30 (Owner: Training manager): publish an “AI-assisted work” micro-policy: when human review is required, what must be documented, and what language is prohibited in client communications. Output: a checklist used in onboarding and CE refreshers.
- Days 31–60 (Owner: Agency/ops manager): implement a supervision rhythm: weekly spot checks of AI-assisted communications and a monthly trend review (top 3 recurring issues + corrective training). Output: a simple scorecard.
- Days 61–90 (Owner: Team leads): run scenario drills: one optimistic, one base, one stress event (e.g., “AI draft misstates coverage,” “chatbot escalates complaint,” “third-party model output conflicts with guideline”). Output: documented remediation steps and updated training notes.
Manager Action Checklist
- Create an AI/tool register (including third-party tools) with an accountable owner for each.
- Define “human-in-the-loop” review points for client-facing communications and key decisions.
- Standardize documentation: what to save (prompt/output, edits, rationale) and where.
- Set a weekly supervision cadence: 10-sample spot check + coaching notes.
- Update onboarding: add an AI workflow module alongside licensing exam prep milestones.
- Align CE planning to operational risk: schedule refreshers before peak renewal/production periods.
Learner Action Checklist
- For exam prep: do timed practice sets and keep a miss log; re-test weak domains within 72 hours.
- Practice writing a compliant coverage explanation in your own words before using any AI draft.
- If you use AI at work: never send client-facing text without reviewing for accuracy and clarity.
- Keep a personal “workflow error log” (miscommunication, unclear terms, missing notes) and review weekly.
- For CE: build a 90/60/30-day completion plan around your renewal deadline and confirm transcript posting.
TSI National can help you build a structured licensing exam prep or CE completion plan that fits your role and timeline as AI-enabled workflows expand.
Source: Original article
Educational information only; verify requirements with your state Department of Insurance.

