HI DOI AI Bulletin
Hawaii Insurance Commissioner Memorandum 2025-13A — Use of AI Systems by Insurers (NAIC Model Bulletin adoption)
HI · Hawaii Insurance Commissioner Memorandum 2025-13A (2025-12-10)
- Status
- In effect
- Took effect
- December 10, 2025
- Applies to
- All insurers licensed to write business in HI (including health, life, P&C, and reinsurance lines)
- Enforced by
- HI Department / Division of Insurance
The HI Department of Insurance adopted the NAIC Model Bulletin on Use of Artificial Intelligence Systems by Insurers. Insurers licensed in HI must maintain a written AI program with governance, risk-management, testing, third-party-AI oversight, and documentation controls. The bulletin operationalizes existing unfair-trade-practice and unfair-discrimination law as applied to insurers' AI use cases — underwriting, pricing, claims, fraud detection, and marketing.
Who is protected: Consumers, applicants, claimants, and policyholders in HI whose insurance decisions involve insurer AI systems
Legal detail
Adoption of the NAIC Model Bulletin on Use of AI Systems by Insurers. Establishes regulator expectations for insurer AI Systems Programs covering governance/accountability, risk identification/mitigation, model validation/testing for bias and accuracy, third-party AI vendor due diligence, ongoing monitoring, and documentation/recordkeeping sufficient to support regulator examination. Existing statutory authority: state unfair trade practices act, unfair discrimination provisions, market-conduct examination authority.
Key facts
| Jurisdiction | HI |
|---|---|
| Level | State |
| Strength | Limited |
| Enacted | December 10, 2025 |
| Citation | Hawaii Insurance Commissioner Memorandum 2025-13A (2025-12-10) |
| Private right of action | No, agency enforcement only |
| Penalties | Standard market-conduct examination findings, corrective action plans, fines under state unfair-trade-practices act |
| Topics | insurance AI · automated decision-making · consumer protection |
| Agency page | NAIC AI Model Bulletin Implementation Map (Apr. 1, 2026) |
Related insurance AI rules elsewhere
- NYDFS CL 7 (2024) — Insurance AI Anti-Discrimination · In effect
- NAIC AI Evaluation Tool Pilot (12 states, 2026) · Proposed / pending
- AZ HB 2175 (AI Insurance Denial — Physician Review) · In effect
- TX TDI Bulletin B-0003-26 (AI in insurance) · In effect
- Illinois SB 3114 — Transparency in Downcoding Act · Enacted (not yet in effect)
- PA AG — GEICO AI Underwriting Settlement · In effect
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