Three Regulators, One Technology: Comparing Supervisory Approaches to Artificial Intelligence in Insurance in Switzerland, the United States and Ghana

Insurance supervisors worldwide confront the same technology, artificial intelligence deployed in pricing, underwriting, reserving and claims, but they confront it from radically different institutional positions, and the templates most visible to late-moving regulators emerge from institutional settings unlike their own. This paper asks whether supervisory responses to a common technology converge on the technology's properties or diverge along institutional lines, and what the answer implies for supervisors that have not yet acted. Using a structured, focused comparison on a most-different-systems design, the paper analyses three supervisory responses across six dimensions, legal form and bindingness, regulatory philosophy, institutional carrier, accountability locus, enforcement mechanism and market context: the Swiss Financial Market Supervisory Authority's Guidance 08/2024, the United States NAIC model bulletin and AI Systems Evaluation Tool, and Ghana's National Insurance Commission, which supervises under a modernised statute and a national artificial intelligence strategy but without, as yet, an insurance-specific instrument. The comparison finds convergence at the level of risk taxonomy and systematic divergence at the level of instrument design, supporting an institutionalist rather than functionalist reading: the three responses constitute distinct equilibria, not points on a maturity curve, and, strikingly, the jurisdiction without an instrument possesses the strongest statutory named-person accountability infrastructure of the three. The paper extends the framework of institutionally contingent technology adoption hierarchies from firms to supervisors and translates the findings into a four-part guideline architecture for capacity-constrained regulators, illustrated for Ghana, that routes delegation-aware, condition-based obligations through enforcement channels the supervisor already controls.