Insurance Cybersecurity Resource
NAIC Model Law evidence for insurance carriers and agencies.
The NAIC Insurance Data Security Model Law turns cybersecurity into an oversight and evidence problem: risk assessment, information security program, incident response, third-party service-provider oversight, and documentation that can be shown when regulators, carriers, or cyber insurers ask.
By Brian Edelman, Founder & CEO, FCI Cyber · Last updated: August 2026
The short version
For insurance organizations, cybersecurity evidence has to extend beyond headquarters.
Carriers, agencies, and financial-services insurance organizations often operate through distributed users, appointed agents, branch offices, vendors, and cloud systems. The hard part is not only writing an information security program. It is showing that the program is enforced across the places where nonpublic information is accessed.
Governance
Risk assessment and program ownership
The organization needs a documented risk assessment, an information security program, and responsible owners who review and update it.
Operations
Controls that operate in the field
Endpoint, MFA, access, backup, encryption, DLP, and monitoring records need to cover users and locations outside the home office.
Oversight
Vendors, agents, and incident response
Third-party relationships and incident workflows need contacts, contracts, response timing, and records that prove follow-through.
Evidence checklist
What insurance organizations should be ready to produce.
State implementations vary, and this page is not legal advice. The recurring operating pattern is clear: regulators and counterparties want proof that the cybersecurity program is risk-based, documented, implemented, and maintained.
| Area | Evidence to prepare |
|---|---|
| Risk assessment | Dated assessment, scope, findings, business/process changes, control decisions, remediation ownership, and annual review history. |
| Information security program | Approved written program, policy mapping, control standards, responsible owner, review cadence, and updates after material changes. |
| Access and authentication | MFA coverage, privileged access reviews, joiner/mover/leaver records, agent or field-user access controls, and exception handling. |
| Endpoint and field-office controls | Device inventory, endpoint protection, patch status, encryption, backup coverage, stale-device reports, and remediation timestamps. |
| Data protection | Where nonpublic information lives, who can access it, DLP/encryption status, disposal procedures, backup/recovery testing, and exfiltration alerts. |
| Third-party oversight | Vendor inventory, service-provider due diligence, contract/security requirements, incident contacts, review dates, and corrective actions. |
| Incident response | Written response plan, roles, escalation workflow, containment records, notification decisions, regulator/insurer communications, and post-incident review. |
Insurance carriers and agencies may need to evidence controls across employees, appointed agents, field locations, vendors, and third-party systems. That makes cybersecurity less like a single IT project and more like an ongoing evidence operation.
FCI helps insurance organizations enforce controls across that distributed environment and produce the records compliance, underwriting, incident response, and leadership teams need when the question becomes: can you prove it?
Build the evidence layer before the request arrives.
Start with the assessment, review cyber-insurance readiness, or ask FCI to map your insurance organization’s users, endpoints, vendors, and incident workflows to the evidence you need.