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AI Governance

AI Insurance Readiness: Six Controls Carriers Require

By Errin O'Connor, Founder & Chief AI Architect, EPC Group

Audit-grade governance evidence for your cyber, Tech E&O, D&O, and EPLI renewal

Source-verified evidence pack from EPC Group on the post-Silent-AI insurance market. ISO CG 40 47/48 (effective January 1, 2026), Beazley/QBE ~10% AI sublimits, the Munich Re/Mosaic / Armilla / Counterpart / Testudo affirmative market, NAIC adoption in 24 states, EU AI Act Article 9, plus the four costed receipts (Bartz, Moffatt, Mobley, Hasbro) and the six controls underwriters now require — mapped to NIST AI RMF, ISO/IEC 42001, and AIUC-1.

14 pages
30-45 minutes
June 2026
New downloads
PDF Document
4.0 MB
EO
Errin O'Connor
Founder & Chief AI Architect

Four-time bestselling author for Microsoft Press and Sams with enterprise consulting experience since 1997. Sat across the table from underwriters at six insurance carriers writing cyber, Tech E&O, and dedicated AI coverage to learn precisely what evidence carriers now require.

What's Inside

  • ISO CG 40 47/48 generative-AI exclusions explained (with attachment trigger language)
  • Beazley/QBE ~10% AI sublimit structure with QBE LLMjacking $250k example
  • Affirmative AI-coverage market map — Munich Re/Mosaic, Armilla at Lloyd's, Counterpart, Testudo
  • Bartz v. Anthropic ~$1.5B settlement — provenance vs training distinction
  • Moffatt v. Air Canada — "static page or chatbot" tribunal ruling
  • Mobley v. Workday — nationwide collective on AI hiring tools
  • Hasbro Q1 2026 ~$20M remediation / $40-60M delayed revenue disclosure
  • Six governance controls mapped to NIST AI RMF, ISO/IEC 42001, AIUC-1
  • The AI Insurability Officer role — delivered via Virtual Chief AI Officer (vCAIO)
  • Microsoft-stack enforcement evidence (Entra workload identity, Purview grounding, Defender/M365 audit)
  • "Multiple Models. One Truth." — multi-model coverage (Claude, GPT, Gemini, Grok, Perplexity)
  • Full source ledger with every carrier, court, and regulatory citation

Table of Contents

1Executive Summary — Silent AI Is Dead
Pages 1-2
2The Four-Front Squeeze (ISO + Sublimits + Affirmative + Regulation)
Pages 3-5
3The Four Receipts (Bartz · Moffatt · Mobley · Hasbro)
Pages 6-8
4The Six Controls Carriers Now Require
Pages 9-11
5The AI Insurability Officer — The Seat No Org Chart Has Drawn Yet
Pages 12
6Multi-Model Coverage on the Microsoft Stack
Pages 13
7Source Ledger (Every Receipt Linked)
Pages 14

Preview

For three years your insurance covered AI losses by silence, not by grant. That era ended on January 1, 2026 — the day the Insurance Services Office (ISO) released three generative-AI exclusion endorsements (CG 40 47 broad, CG 40 48 limited, CG 35 08 products/completed-operations) attachable at every Commercial General Liability renewal. In parallel, cyber carriers including Beazley and QBE began introducing AI sublimits around 10% of policy limits, while a new affirmative AI-coverage market — Munich Re/Mosaic, Armilla at Lloyd's, Counterpart, Testudo — emerged that underwrites only on documented governance evidence. This evidence pack is the source-verified breakdown of what changed, what it costs, and what the six insurance carriers we met with said they now require before they will quote or renew AI-touching coverage. Every claim traces to a verified source ledger: ISO form numbers, FT reporting on Beazley/QBE, Munich Re/Mosaic capacity, AIUC-1 standard alignment, NAIC Model Bulletin adoption count, EU AI Act Article 9, plus the four costed receipts (Bartz v. Anthropic ~$1.5B, Moffatt v. Air Canada, Mobley v. Workday, Hasbro Q1 2026 ~$20M). EPC Group is not an insurance company, broker, or producer and does not sell, place, or provide insurance. This pack documents the governance evidence enterprises and their brokers present to underwriters — assembled to recognized standards (NIST AI RMF, ISO/IEC 42001, AIUC-1) and mapped, for multinational exposure, to EU AI Act Article 9.

Who Should Read This

  • Chief Financial Officers (renewal signers)
  • General Counsel and Legal teams
  • Chief Risk Officers and Risk Management
  • Board Audit Committees
  • Chief Information Security Officers
  • Insurance brokers serving Microsoft-stack enterprises
  • Chief AI Officers and AI Program Leaders

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