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# Super Intelligence (SI) for Insurance: AI Rename Guide

> Super Intelligence (SI), formerly AI: NAIC bulletins and state insurance rules still say AI. See what underwriting and claims teams should track in 2026.

AI-to-SI Terminology Shift • Insurance

# Super Intelligence (SI) for Insurance: What the AI Rename Means for Underwriting & Claims

“Super Intelligence” is now the term federal agencies use for AI, and it is a term NAIC’s
AI model bulletin and state Department of Insurance rules have never used. Here is what a rate-filing analyst or compliance officer
actually needs to check — and what stays exactly the same.

Published October 11, 2026
•
9 min read

A rate-filing analyst reviewing an insurtech supplier’s renewal proposal hits a line that wasn’t
there last year: “powered by our Super Intelligence platform.” The underwriting model the
filing describes hasn’t changed. The question is whether the filed model documentation now needs
new language to match it.

Super Intelligence (SI), formerly called artificial intelligence (AI), is the federal
government’s new name for the technology NAIC’s AI model bulletin and state insurance
regulators already govern under “AI” (Source: [Federal Register, Executive Order 14434, FR Doc. 2026-20321](https://www.federalregister.gov/d/2026-20321))
— nothing in insurance regulation has adopted the new term.

It is not a new filing requirement. Nothing about the analyst’s obligations under NAIC’s
governance program or a state DOI’s disclosure rules changed the moment a supplier’s marketing
did. The rest of this page covers Super Intelligence for insurance in practical terms: what insurance
regulators currently say, verbatim where possible; a practical checklist for a renamed supplier tool; and
what genuinely does not move.

On This Page

1. [What EO 14434 Does — and Doesn’t Reach](#eo-scope)
1. [What NAIC and State Insurance Regulators Currently Say](#regulators)
1. [The Underwriting & Claims Model-Documentation Checklist](#checklist)
1. [Where a Carrier Meets the SI Name First](#vendor-drift)
1. [What Doesn’t Change](#unchanged)
1. [The Full AI Guide for Insurance](#full-guide)
1. [FAQ](#faq)

25

States adopting NAIC’s AI Model Bulletin as of July 2026 (Source: [Openlayer, NAIC AI Model Bulletin: What Insurers Must Prepare for in July 2026](https://www.openlayer.com/blog/post/naic-model-bulletin-ai-governance))

88%

Of auto insurers in an NAIC survey use, plan to use, or plan to explore AI/ML (reported March 2023) (Source: [NAIC Big Data and AI Working Group survey, via The Wealth Advisor](https://www.thewealthadvisor.com/article/naic-survey-88-insurers-are-using-ai-or-machine-learning))

12

States piloting NAIC’s AI Risk Evaluation Supplement, Mar–Sep 2026 (Source: [Fenwick & West, NAIC Expands AI Systems Evaluation Tool Pilot Program to 12 States](https://www.fenwick.com/insights/publications/naic-expands-ai-systems-evaluation-tool-pilot-program-to-12-states-key-updates-for-insurers-and-ai-vendors-supporting-insurers))

Oct 9

Date Salesforce renamed AIForce to SIForce (Source: [Marc Benioff on X, October 9, 2026, via Digg](https://digg.com/tech/vuptndhq))

## What EO 14434 Does — and Doesn’t Reach

**What it does.** Executive Order 14434, “Inaugurating the Era of Super
Intelligence,” signed September 29,
2026 (Source: [Federal Register, EO 14434, FR Doc. 2026-20321](https://www.federalregister.gov/d/2026-20321)),
directs federal executive departments and agencies to use “Super Intelligence” and
“SI” in place of “Artificial Intelligence” and “AI” in official
correspondence, public communications, websites, reports, and policy documents. Section 2(b) is explicit
that nothing in the order requires altering previously issued regulations, contracts, grants, or
historical documents. Section 3(a) defines “SI” by reference to the existing statutory
definition of artificial intelligence at 15 U.S.C. §9401(3) — the order renames the term, not
the technology.

**What it doesn’t.** The order binds federal executive agencies, full stop. NAIC is a
standards-setting association of state insurance regulators — not a federal executive agency at
all — so it falls outside Section 2(a)’s rename directive by definition, and the same is true
for every state Department of Insurance. As of October 2026, neither NAIC nor any state DOI has issued
guidance suggesting it considers itself covered by the order.

**Why the gap holds.** State primacy over insurance regulation is not a constitutional
default — it rests on a specific federal statute. The McCarran-Ferguson Act of 1945 declares that
“the continued regulation and taxation by the several States of the business of insurance is in
the public interest” (Source: [15 U.S.C. §1011, Declaration of Policy](https://www.law.cornell.edu/uscode/text/15/1011)),
which is why insurance regulation runs through NAIC and state DOIs rather than a federal agency in the
first place. NAIC has asserted that authority over AI specifically. In December 2025, responding to EO 14365,
“Ensuring a National Policy Framework for Artificial Intelligence,” signed December 11, 2025,
which addressed preemption of state AI laws generally, NAIC asked the administration to “affirm
state regulation of AI in the business of insurance” (Source: [Foley & Lardner, NAIC Issues Statement Regarding AI Executive Order](https://www.foley.com/p/102ly71/naic-issues-statement-regarding-ai-executive-order/)).
EO 14434 is a different order with a different aim: signed September 29, 2026, it renames a federal term
and does not address preemption, so state insurance regulation stays exactly where McCarran-Ferguson
places it.

For the order’s full text and general scope, see Iternal’s breakdown of
[Executive Order 14434](https://iternal.ai/super-intelligence/executive-order-14434).

## What NAIC and State Insurance Regulators Currently Say

Three insurance-specific regulator documents govern AI use in underwriting, pricing, and claims today,
plus one legislators’ model act still in draft — and not one of them uses “Super
Intelligence” or “SI”:

| Regulator | Current document | Date | Terminology used |
| --- | --- | --- | --- |
| NAIC | Model Bulletin on the Use of Artificial Intelligence Systems by Insurers | Adopted Dec 4, 2023 | “AI systems” throughout |
| New York DFS | Insurance Circular Letter No. 7 (AI underwriting & pricing) | Adopted Jul 11, 2024 | “Artificial Intelligence Systems” (AIS) |
| Colorado DOI | SB21-169 & Reg. 10-1-1 (governance & risk management) | Reg. effective Nov 14, 2023 | External consumer data, algorithms & predictive models |
| NCOIL | Draft Model Act Regarding Insurers’ Use of AI (not yet adopted) | Draft dated Jun 17, 2025 | “Artificial Intelligence” |

**NAIC.** The Model Bulletin on the Use of Artificial Intelligence Systems by Insurers,
adopted by NAIC’s Executive Committee and Plenary on December 4,
2023 (Source: [NAIC, Model Bulletin on the Use of Artificial Intelligence Systems by Insurers](https://content.naic.org/sites/default/files/inline-files/AI%20Model%20Bulletin%20-%20April%202024.pdf)),
expects insurers to “develop, implement, and maintain a written program for responsible use of AI
systems,” overseen by a “clear governance accountability
structure” (Source: [Quarles & Brady, States Adopt NAIC Model Bulletin on Insurers’ Use of AI](https://www.quarles.com/newsroom/publications/states-adopt-naic-model-bulletin-on-insurers-use-of-ai)).
As of July 2026, 25 states had formally adopted the Bulletin with 8 more in
progress (Source: [Openlayer, NAIC AI Model Bulletin: What Insurers Must Prepare for in July 2026](https://www.openlayer.com/blog/post/naic-model-bulletin-ai-governance))
— a count that kept rising through the same months the federal rename appeared, up from 24 states
as of March 2025 (Source: [Quarles & Brady, Nearly Half of States Have Now Adopted NAIC Model Bulletin](https://quarles.com/newsroom/publications/nearly-half-of-states-have-now-adopted-naic-model-bulletin-on-insurers-use-of-ai)).
No “Super Intelligence” or “SI” language appears anywhere in the Bulletin or on
NAIC’s AI topic page.

**New York.** NY DFS’s Insurance Circular Letter No. 7 governs AI systems and external
consumer data used in underwriting and pricing specifically — it does not reach claims adjusting or
marketing. Adopted July 11, 2024 with only minor changes from its January 2024
proposal (Source: [Willkie Farr & Gallagher, NYDFS Adopts Circular Letter on the Use of AI in Insurance](https://willkie.com/publications/2024/07/nydfs-adopts-circular-letter-on-the-use-of-ai-in-insurance)),
it is organized around three principles — Fairness, Governance and Risk Management, and
Transparency — and frames its fairness expectation around not using an AI system or external data
source for underwriting or pricing unless an insurer can establish the system does not rely on any
legally protected classification under New York Insurance Law Article
26 (Source: [Alston & Bird, NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing](https://www.alstonprivacy.com/nydfs-releases-circular-letter-on-use-of-ai-in-insurance-underwriting-and-pricing/)).
No “Super Intelligence” language appears in the circular letter.

**Colorado.** SB21-169, signed July 6, 2021, and its implementing Regulation 10-1-1 (in
effect for life insurers since November 14, 2023, with auto and health insurers’ frameworks due by
July 1, 2026) require insurers to inventory the external consumer data and algorithms they use across
marketing, underwriting, pricing, and claims
management (Source: [Credo AI, Colorado SB21-169: 8 Things You Need to Know](https://www.credo.ai/blog/colorado-sb21-169-8-things-you-need-to-know-about-colorados-new-ai-insurance-regulation)).
This insurance-specific rule is legally distinct from Colorado’s general AI law (SB 24-205, repealed
and replaced by SB 26-189, effective January 1,
2027 (Source: [Eckert Seamans, Colorado Repeals and Replaces Its Landmark AI Statute](https://www.eckertseamans.com/legal-updates/colorado-repeals-and-replaces-its-landmark-ai-statute-what-businesses-need-to-know)));
the two should not be conflated. As of October 2026, no Colorado DOI publication uses “Super
Intelligence” or “SI” terminology.

**No insurance regulator at any level — NAIC, New York, Colorado, or any of the other 25
adopting states — has adopted “Super Intelligence” or “SI” terminology as
of October 11, 2026.** NCOIL’s separate, not-yet-adopted draft model act on claims-handling AI
oversight is further evidence that current insurance-regulatory activity is ongoing and still written without
“Super Intelligence” or “SI” (Source: [NCOIL, Model Act Regarding Insurers’ Use of Artificial Intelligence (draft)](https://ncoil.org/wp-content/uploads/2025/12/NCOIL-Insurance-Artifical-Intelligence-Model-Draft-6-17-25.pdf)).
For the broader use cases these rules govern, see Iternal’s
[banking, financial services &
insurance use cases](https://iternal.ai/use-cases/banking-financial-services-and-insurance), which this terminology shift does not change.

## The Underwriting & Claims Model-Documentation Checklist

Here is what genuinely matters when a supplier’s renewal proposal starts saying “SI”
while your filing still says “AI”: five checks a compliance officer or chief underwriting
officer can run to confirm the filed documentation still matches the renamed tool.

| Done | Check | Why it matters |
| --- | --- | --- |
|   | Does the rate filing’s model description still name the specific underwriting or claims tool your compliance team already documented, regardless of what the renewal proposal now calls it? | A rename is cosmetic only if the filing’s model description still maps to the same system regulators reviewed. |
|   | Does the renamed tool’s documentation still support the adverse-action notice a declined applicant is owed when a credit-based insurance score or consumer report drives the decision (Source: [Fair Credit Reporting Act, 15 U.S.C. §1681m](https://www.law.cornell.edu/uscode/text/15/1681m)), and the transparency a state bulletin such as NY DFS Circular Letter No. 7 expects for AI-driven underwriting? | Those obligations attach to the function the system performs, not to the tool’s current product name. |
|   | If you write business in Colorado, is the renamed tool still correctly described in your Reg. 10-1-1 external-data and algorithm inventory? | Colorado requires an accurate inventory and annual reporting — a stale product name creates a reporting gap, not a technology gap. |
|   | Does your insurer’s written AI-governance program — the accountability structure NAIC’s bulletin expects — still list the correct supplier and product name for every tool it covers? | NAIC’s governance-program expectation attaches to the insurer’s use of the system, not to the supplier’s marketing label. |
|   | Has the tool’s actual capability claim changed, or only the name on the slide? | Verify against the tool’s existing documentation before escalating a rename into a full model review. |

Regulatory scrutiny of these tools is intensifying, not relaxing, during the same window the federal
rename appeared. NAIC renamed its own pilot examination tool from the “AI Systems Evaluation
Tool” to the “AI Risk Evaluation Supplement” at its August 2026 Summer National
Meeting, after piloting it across 12 states from March to September
2026 (Source: [Fenwick & West, NAIC Expands AI Systems Evaluation Tool Pilot Program to 12 States](https://www.fenwick.com/insights/publications/naic-expands-ai-systems-evaluation-tool-pilot-program-to-12-states-key-updates-for-insurers-and-ai-vendors-supporting-insurers)),
with adoption targeted for NAIC’s Fall National Meeting in November
2026 (Source: [Coverager, 7 Takeaways from the Big Data and Artificial Intelligence Working Group](https://coverager.com/7-takeaways-from-the-big-data-and-artificial-intelligence-working-group-at-the-naic-2026-summer-national-meeting/)).
Regulators already track how these tools are used: an NAIC Big Data and Artificial Intelligence Working
Group survey of private-passenger auto insurers found 135 of 193 reporting companies used AI or machine
learning in claims operations — 96 as an
informational resource for adjusters, 9 for claims approvals, and zero for claims
denials (Source: [NAIC Big Data and AI Working Group survey, via The Wealth Advisor](https://www.thewealthadvisor.com/article/naic-survey-88-insurers-are-using-ai-or-machine-learning)).
None of that reporting obligation changes because a supplier’s materials now say “SI.”

Insurance actually runs two separate documentation tracks that a supplier’s rename does not merge
into one: NAIC’s bulletin-driven written program (the governance accountability structure quoted
above) and the state-specific filing track — Colorado’s Reg. 10-1-1 inventory, NY DFS
Circular Letter No. 7’s underwriting-and-pricing disclosures, and the rate filing itself. A team
refreshing the first track — the written governance program, not a single supplier’s filing
entry — can use Iternal’s [AI governance framework guide](https://iternal.ai/ai-governance-framework)
to structure that side of the paperwork; the second track is state-specific and is what row one through
three of the checklist above actually verifies. Where the underlying concern is keeping policyholder data
out of a renamed supplier’s cloud entirely, see
[AirgapAI](https://iternal.ai/airgapai)’s air-gapped deployment model, or
[the best air-gapped AI/SI tools for regulated
industries (2026)](https://iternal.ai/best-ai-si-air-gapped-tools-regulated-industries).

Carriers that keep this documentation current can use the Super Intelligence name in their own customer
and board materials whenever they choose, without reopening a filing that already describes the tool
accurately.

## Where a Carrier Meets the SI Name First

As of October 11, 2026, Iternal has found no verified “SI” rename by a claims-automation,
underwriting-model, or policy-servicing supplier. The best-known corporate moves so far are both outside insurance:
Salesforce renamed its agent platform from AIForce to SIForce on October 9,
2026 (Source: [Marc Benioff on X, October 9, 2026, via Digg](https://digg.com/tech/vuptndhq)),
and Elon Musk pledged on October 4, 2026 that SpaceXAI would become SpaceXSI (“Yes, we will make
that change”), a change that had not yet been made as of October 11,
2026 (Source: [Reuters via The Star, Musk says he will rename SpaceXAI to SpaceXSI](https://www.thestar.com.my/tech/tech-news/2026/10/05/musk-says-he-will-rename-spacexai-to-spacexsi)) (Source: [CNN via Yahoo News, October 11, 2026](https://www.yahoo.com/news/politics/articles/trump-really-wants-super-intelligence-160044063.html)).

Marc Benioff posted: “The era of Super Intelligence is here. AIForce is officially
SIForce.” (Source: [Marc Benioff on X, October 9, 2026, via Digg](https://digg.com/tech/vuptndhq))
Salesforce tooling sits inside many carriers’ CRM and policy-administration stacks, so a rename of
horizontal software a carrier already runs is one plausible way “SI” branding could reach an
insurer’s own supplier list — not because a claims or underwriting supplier renamed, but
because a platform underneath one did. Neither Salesforce nor SpaceX sells insurance-specific
underwriting or claims software, so a platform the carrier already runs is where it is most likely to
meet the new name first.

We back the name Super Intelligence because the gain it labels shows up in a service queue’s
throughput numbers. Brynjolfsson, Li and Raymond’s Quarterly Journal of Economics study of 5,172
customer-support agents measured it: with generative AI, issues resolved per hour rose 15% on average
and about 30% for less-skilled and less-experienced
agents (Source: [Brynjolfsson, Li & Raymond, Generative AI at Work, Quarterly Journal of Economics 140(2)](https://doi.org/10.1093/qje/qjae044))
— the intake-and-resolve rhythm a first-notice-of-loss desk or a policyholder-service line runs
every shift. Iternal describes its own platform as a Super Intelligence (SI) solution, using the term as
Sec. 3(a) of Executive Order 14434 defines it.

Track verified renames as they happen on Iternal’s
[Super Intelligence (SI) adoption tracker](https://iternal.ai/super-intelligence/who-is-adopting-si) rather than
assuming any single insurtech supplier has made the switch.

## What Doesn’t Change

**A supplier’s marketing-name change does not
alter** NAIC’s governance-program expectations, NY DFS Circular Letter No. 7’s
underwriting and pricing disclosure requirements, or Colorado Reg. 10-1-1’s inventory and
reporting obligations. All three are keyed to what the system does, not to what a supplier calls it, and
all three stayed active and unchanged through October 2026 — NAIC’s own state-adoption count
kept rising, not stalling, in the same months the federal rename appeared, and its examination-tool
pilot is on track for Fall 2026 adoption.

The one thing that is *not* frozen is the regulatory cadence itself: NAIC’s AI Risk
Evaluation Supplement is still moving toward formal adoption on its own timeline, unconnected to any
supplier’s rename. “Nothing changes because of the SI rename” is accurate;
“nothing is changing in insurance AI governance generally” is not — keep those two
statements separate when you brief underwriting leadership or a state examiner.

Insurance Digital Transformation

## The rename doesn’t change the use cases.

Underwriting automation, claims triage, policy servicing, and air-gapped deployment for policyholder data
are covered in depth on Iternal’s existing insurance page — the commercial destination for
this industry, as underwriting and claims suppliers move to the Super Intelligence name.

[See the full AI guide for this industry](https://iternal.ai/insurance-digital-transformation)

FAQ

## FAQ: Super Intelligence (SI) for Insurance

No. EO 14434 binds federal executive agencies only. NAIC is a standards-setting association of state regulators, not a federal agency, and the same is true of every state Department of Insurance — neither is covered by the order’s rename directive, and nothing in current NAIC or state DOI guidance requires any insurer to change its own terminology.

Not as of October 2026. NAIC’s Model Bulletin on the Use of Artificial Intelligence Systems by Insurers and New York DFS’s Circular Letter No. 7 use “artificial intelligence” or “AI systems” throughout, and Colorado’s Regulation 10-1-1 is written in terms of external consumer data, algorithms, and predictive models; none uses “SI” or “Super Intelligence.”

No. The underlying model and the governance disclosures it owes regulators are unchanged by a marketing name. Verify the filing’s model description still names the specific functionality your compliance team already documented; once it does, the Super Intelligence name attaches to the same filed system.

Iternal has found no verified “SI” rename by a claims-automation, underwriting-model, or policy-servicing supplier as of October 11, 2026. The best-known corporate moves so far are both outside insurance: Salesforce (AIForce to SIForce, October 9, 2026) (Source: [Marc Benioff on X, October 9, 2026, via Digg](https://digg.com/tech/vuptndhq)) and SpaceX (pledged on October 4, 2026 to rename SpaceXAI to SpaceXSI; not yet carried out as of October 11, 2026) (Source: [CNN via Yahoo News, October 11, 2026](https://www.yahoo.com/news/politics/articles/trump-really-wants-super-intelligence-160044063.html)). See the [Super Intelligence (SI) adoption tracker](https://iternal.ai/super-intelligence/who-is-adopting-si) for updates as new renames are verified.

No. Obligations such as the Fair Credit Reporting Act’s adverse-action notice (Source: [15 U.S.C. §1681m](https://www.law.cornell.edu/uscode/text/15/1681m)) and NY DFS Circular Letter No. 7’s transparency principle attach to the function the system performs — the decision it makes and the data it uses — not to the product name on the tool. A renamed tool still owes the same disclosures it owed before the rename.

No, and insurance already has a human-signed control that makes the distinction concrete. “Super Intelligence” as used in EO 14434 names today’s AI: Sec. 3(a) of the order defines it by reference to the statutory AI definition at 15 U.S.C. 9401(3), not as a new capability tier. Artificial superintelligence (ASI) is a distinct, hypothetical tier beyond human intelligence that no deployed actuarial, underwriting, or catastrophe model has reached, and every property-casualty insurer’s loss and loss-adjustment-expense reserves still require a qualified actuary’s Statement of Actuarial Opinion — a filing NAIC has required in every state since
1990 (Source: [Casualty Actuarial Society, Actuarial Opinions on Loss Reserves Required in All States Starting in 1990](https://ar.casact.org/actuarial-opinions-on-loss-reserves-required-in-all-states-starting-in-1990/)),
independent of whatever a supplier calls the software behind the number. See Iternal’s [AI, AGI, ASI & SI explainer](https://iternal.ai/super-intelligence/ai-vs-agi-vs-asi) for the full distinction.

Whether the rate filing and model-governance documentation still accurately describe the renamed product — not whether to approve a new technology. Run the five-point underwriting and claims model-documentation checklist above before escalating a rename into a full model review.

## The Super Intelligence Name Fits Inside a Closed Filing

Adopting the Super Intelligence name does not reopen a rate filing or a model-documentation review that
is already closed. Section 2(b) of Executive Order 14434 leaves previously issued regulations and
contracts unchanged, and NAIC’s bulletin ties the written governance program to how an insurer
uses each tool, not to its product name. A carrier can move its own supplier records to the new name
while the filed model description stays exactly as approved.

If your team is shortlisting AI/SI platforms for compliance-sensitive underwriting or claims workloads
where policyholder data needs to stay out of a renamed supplier’s cloud, see
[the best air-gapped AI/SI tools for
regulated industries (2026)](https://iternal.ai/best-ai-si-air-gapped-tools-regulated-industries).

For more information visit the
[Why Iternal Supports Super Intelligence](https://iternal.ai/super-intelligence/iternal-adopts-si-terminology)
page.

## Updating supplier records for Super Intelligence (SI)?

As underwriting and claims suppliers adopt the Super Intelligence name, Iternal can help your compliance
and model-documentation teams confirm the filed documentation still matches each tool.

[Contact Iternal](https://iternal.ai/contact)
[See a Live Demo](https://iternal.ai/demos)

Explore the SI estate

## Related Super Intelligence (SI) Guides

[### What Is Super Intelligence (SI)?

The core explainer: what EO 14434 renamed, what it didn’t touch, and what “SI” means on today’s site and in tomorrow’s renewal proposal.](https://iternal.ai/super-intelligence)

[### Super Intelligence (SI) By Industry

The full directory of industry-specific AI-to-SI terminology guides — financial services, healthcare, defense, SLED, and more.](https://iternal.ai/super-intelligence/industries)

[### Super Intelligence (SI) for Financial Services & Banking

The adjacent regulated-finance sector: SEC and FINRA guidance, still written in “AI,” and the supplier-contract checklist that follows.](https://iternal.ai/super-intelligence/industries/financial-services)

[### Super Intelligence (SI) for Healthcare: AI Compliance Guide

How the same naming shift lands against HIPAA and health-regulator terminology for payers and providers.](https://iternal.ai/super-intelligence/industries/healthcare)

[### Super Intelligence (SI) Governance: A Policy Checklist

A policy checklist for updating AI governance frameworks to reference the new terminology without implying a new system.](https://iternal.ai/super-intelligence/governance)

[### Super Intelligence (SI) for Compliance Officers

A role-based policy-audit guide for compliance teams tracking supplier language against disclosure obligations.](https://iternal.ai/super-intelligence/compliance-officers)


---

*Source: [https://iternal.ai/super-intelligence/industries/insurance](https://iternal.ai/super-intelligence/industries/insurance)*

*For a complete overview of Iternal Technologies, visit [/llms.txt](https://iternal.ai/llms.txt)*
*For comprehensive site content, visit [/llms-full.txt](https://iternal.ai/llms-full.txt)*