Score inherent risk based on the exact insurance use, then apply
mandatory overrides. The final tier sets the minimum governance,
testing, approval, and monitoring requirements.
Risk factors
Rate inherent risk before planned controls
IB-01Consumer and business impact
Consumer impact
How directly can the use affect an applicant, policyholder,
claimant, beneficiary, producer, or employee?
0No individual impact; internal support only
1Indirect or informational impact
2Material influence on service, prioritization, or
decision
3Determines or executes an eligibility, pricing, coverage,
claim, fraud, employment, or other consequential outcome
Is the proposed use prohibited, not legally supportable, outside
risk appetite, or inconsistent with approved company policy?
If yes Do not deploy. Escalate to Legal, Compliance, Risk,
and the accountable executive.
OV-02TIER 4
Automated consequential decision
Can the system determine or execute an adverse or consequential
consumer outcome without meaningful human review before the
outcome?
If yes Apply Tier 4 controls and obtain executive risk
acceptance before any production use.
OV-03TIER 4
Binding or autonomous authority
Can the system autonomously bind coverage, change policy terms,
approve or deny a claim, set or transfer material funds, execute
settlement, or make another legally binding commitment?
If yes Apply Tier 4 controls, strict transaction limits,
confirmations, separation of duties, and tested kill switches.
OV-04TIER 4
Safety or systemic exposure
Could failure create physical safety risk, prevent a critical
insurance service, or produce severe correlated impact across a
large portfolio or population?
If yes Apply Tier 4 controls, independent assurance,
resilience testing, and executive approval.
OV-05MINIMUM TIER 3
Sensitive consequential use
Does the use materially influence underwriting, pricing, coverage,
claims, fraud, employment, or another consequential decision using
sensitive data, external consumer data, inferred attributes, or
potential proxies?
If yes Require fairness, proxy, data, explanation, legal,
and consumer-outcome controls before pilot or production.
OV-06MINIMUM TIER 3
Agentic external action
Can a generative or agentic system use external tools, write to
production records, send external communications, or act on
untrusted content?
If yes Require threat modeling, prompt-injection testing,
least privilege, action controls, traceability, and rollback.
Minimum control requirements
Company policy and applicable law may require more
Control
Tier 1
Tier 2
Tier 3
Tier 4
Accountable business owner and inventory record
Required
Required
Required
Required
Documented purpose, boundaries, users, data, and prohibited
uses
Basic
Detailed
Detailed
Executive-approved
Legal, compliance, privacy, and security review
As needed
Targeted
Required
Required plus executive review
Independent validation and challenge
Optional
Risk-based
Required
Required with enhanced independence
Fairness, proxy, and consumer-outcome testing
If relevant
If relevant
Required for consequential use
Required before and during use
Human oversight and override testing
Basic
Documented
Tested
Demonstrably effective and monitored
Security, abuse, and prompt-injection testing
Baseline
Targeted
Required
Independent red team or equivalent
Production monitoring and incident response
Basic
Defined metrics
Thresholds and escalation
Continuous or near-real-time
Change approval and reassessment
Material changes
Defined changes
Formal approval
Formal approval plus rollback test
Approval authority
Business owner
Business and control owners
AI governance committee
Executive risk committee or delegated governing body