The NAIC Insurance Data Security Model Law (MDL-668) has now been adopted by most US states, requiring licensed insurers, agents and other regulated entities to maintain a comprehensive information security program that includes regular testing of key controls — explicitly naming penetration testing and vulnerability assessment as expected methods.
We deliver that testing mapped to your information security program, in a format your state insurance regulator recognises.
We test the systems handling nonpublic information as defined by the Model Law, and structure findings to support your annual certification of compliance to your domiciliary state regulator, alongside a review of the broader information security program the law requires.
Why it matters
MDL-668 adoption is now widespread across US states, and it explicitly requires annual certification of compliance signed by a senior executive — not something to leave resting on untested assumptions. Insurers found to have gaps after a breach face both regulatory action and the reputational fallout of failing to protect policyholder data.
What we test
- Nonpublic information systems penetration testing
- Access control & authentication testing
- Encryption implementation review
- Third-party service provider oversight review
- Incident response plan validation
- Annual certification evidence package
Common vulnerabilities we uncover
- Nonpublic information reachable through weak access controls
- Encryption gaps in data at rest or in transit
- Third-party service providers with unreviewed access to policyholder data
- No documented, tested incident response plan
- Missing evidence for the required annual certification
- Information security program that exists on paper but is untested
Our methodology
- Scoping & rules of engagement. We agree objectives, targets and boundaries for your naic insurance data security penetration testing, so testing is safe, authorized and focused on what matters to your business.
- Reconnaissance & mapping. We enumerate the full attack surface in scope, building a complete picture before any exploitation begins.
- Manual exploitation. Our senior testers chain vulnerabilities by hand — going far beyond automated scanners — to prove real, demonstrable impact.
- Analysis & reporting. Every finding is triaged, risk-rated with CVSS and written up with a copy-paste reproduction and clear remediation.
- Remediation support & free retest. We support your team through the fixes and retest the remediated issues to confirm they are genuinely closed.
Tools & techniques
We test the systems handling nonpublic information under the Model Law's definition, review access controls, encryption and third-party service provider oversight, and structure the resulting report to support the annual certification your board or senior executive must sign for your domiciliary regulator.
When you need this engagement
- You are a licensed insurer, agent or other entity regulated under an adopted Model Law state
- Your annual certification of compliance is due
- You need technical testing evidence for your information security program
- A state regulator has requested evidence following an examination
- You are building your information security program to meet MDL-668
What you receive
- Penetration test report scoped to nonpublic information systems
- Access control & encryption findings
- Third-party oversight review
- Incident response readiness validation
- Annual certification evidence package
- Free retest after remediation
What’s included in your report
Every naic insurance data security penetration testing engagement concludes with a comprehensive, board-ready report and a working session to walk your team through it. Your report includes:
- An executive summary with overall risk posture for non-technical stakeholders
- Detailed technical findings, each with a step-by-step, copy-paste reproduction
- CVSS v3.1 severity ratings and business-impact context for every issue
- Prioritized, actionable remediation guidance your engineers can apply directly
- A complimentary retest to confirm fixes and update finding status
- A formal attestation letter for customers, auditors and compliance programs
Standards & frameworks
NAIC Insurance Data Security Model Law (MDL-668)
Outcomes you can expect
After your naic insurance data security penetration testing, you will have clear, evidence-based visibility into your real security risk — not a scanner’s guesswork. You will know exactly which weaknesses an attacker could exploit, what the business impact would be, and the precise steps to fix them in priority order. Teams use our findings to close critical gaps, satisfy customer and regulator security requirements, and demonstrate due diligence to their board. With a complimentary retest included, you also get documented proof that the issues are genuinely resolved.
Engagement details & logistics
Every naic insurance data security penetration testing starts with a short, no-obligation scoping call to understand your goals, environment and constraints, followed by a fixed-price proposal and a clear statement of work. Most engagements are delivered fully remotely, with on-site work arranged where it genuinely adds value. Throughout testing we maintain an agreed communication cadence and escalate any critical, high-impact finding to you immediately rather than waiting for the final report. All work is performed under a signed NDA with strict data-handling controls, using safe, non-disruptive techniques and carefully coordinated rules of engagement to protect your production systems. On completion you receive your report and a walkthrough session, followed by a complimentary retest once your fixes are in place. Typical engagements are booked one to three weeks in advance, and urgent or pre-deadline testing can often be accommodated — just ask at hi@agentoffense.com.
Why organizations choose AgentOffense
Our naic insurance data security penetration testing is delivered by senior offensive-security engineers who test the way real attackers do — manually, creatively and with a relentless focus on proving genuine, demonstrable impact. Here is what sets our engagements apart:
- Manual, exploit-driven testing that chains vulnerabilities the way a real attacker would, going far beyond what automated scanners can find.
- Reproducible proof for every finding, with copy-paste reproduction steps your engineers can follow and independently verify.
- Honest severity calibration so you invest in fixing what genuinely matters and avoid wasting effort on false positives and noise.
- Clear, business-focused reporting that speaks to engineers and executives alike, tying every issue to real-world impact.
- A complimentary retest included, so you get documented proof that your fixes actually close the attack path.
- Responsible, collaborative delivery with a named point of contact and secure handling of all data throughout the engagement.
Explore related services
NAIC Insurance Data Security Penetration Testing is frequently scoped alongside our other offensive-security services for broader coverage. Explore related engagements that complement it:
How much does NAIC Insurance Data Security Penetration Testing cost?
Every naic insurance data security penetration testing is scoped and priced individually, so you pay for exactly the coverage you need — with no hidden extras. After a short, no-obligation scoping call we send a fixed-price quote, usually within one business day, with clear deliverables, a firm timeline and a complimentary retest included. The price of your naic insurance data security penetration testing depends on the size and complexity of the target and the depth of testing required, so you always know the cost up front before any work begins.
Get a fixed-price quote
Frequently asked questions
Does the NAIC Model Law require penetration testing?
Yes — MDL-668 explicitly names penetration testing and vulnerability assessment among the methods expected to validate the effectiveness of your information security program's key controls.
Which states have adopted this law?
Most US states have now adopted a version of the NAIC Model Law, though specific requirements and effective dates vary — we help you confirm what applies to your domiciliary state and any others you are licensed in.
Who has to sign the annual certification?
Typically a senior executive or the board, certifying compliance to your domiciliary regulator — which is exactly why documented, current testing evidence matters before that signature goes on record.
How does this relate to GLBA?
They overlap significantly for insurers also subject to GLBA's Safeguards Rule, and we can align a single testing engagement to support both sets of requirements.