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The AI Systems Program (AIS Program) every insurer should run

AI Systems Program جو ہر انشورر کو چلانا چاہیے

35 min read

Three ways to see it

  1. The AIS Program is not one document but a small library. It contains the policy statement signed by the board, the inventory of AI systems, the governance structures, the risk management procedures, the testing and validation protocols, the third-party management approach, the consumer disclosure approach, the incident response plan, and the training plan for staff. Together it is 30 to 80 pages depending on the size of the insurer. The point is that every one of these elements actually exists, not that they fit a templated word count.

  2. Way one to begin: write the one-page policy statement first. Two paragraphs on principles (often borrowing UNESCO and NAIC FACTS), two paragraphs on the governance bodies (AI committee, model risk function, compliance), two paragraphs on roles (Chief AI Officer or designated executive, audit committee oversight), one paragraph on the review cadence. The policy statement is the spine; everything else hangs off it.

  3. Way two: build the inventory next. Walk every department: actuarial, underwriting, claims, fraud, distribution, customer service, HR, finance. Ask: do you use any AI here? Often the answer is yes through a vendor tool the central IT team did not know about. The inventory becomes a real document only when every department head has signed it. Pakistani insurers regularly discover, on doing this honestly, that they have 20 to 40 AI systems they did not know they had.

Quick check

Quick check: what makes modern AI different from a rule-based program?

The why-tree

Why-tree level one: why a written program, not just principles? Because principles drift; written programs are auditable. Examiners look for documents, not declarations.

Try this with Claude

AI-edge prompt to try: 'Acting as a NAIC-style examiner, give me the table of contents of a complete AIS Program for a Pakistani life insurer. For each section name the document type, the typical length, and the owner inside the company.' Use as a planning template.

Sources

Sources and further reading. NAIC Model Bulletin on AI by Insurers, December 2023, AIS Program section. NAIC Big Data and Artificial Intelligence Working Group reports. IAIS Application Paper on the Supervision of AI. EIOPA AI Governance Principles. SECP Pakistan Insurance Rules. ISO/IEC 42001:2023 AI Management Systems. Anthropic Responsible Scaling Policy.