Iowa Insurance Division Bulletin 24-04 — Use of AI Systems by Insurers (NAIC Model Bulletin adoption)
IA · Iowa Insurance Division Bulletin 24-04 (2024-11-07)
The IA Department of Insurance adopted the NAIC Model Bulletin on Use of Artificial Intelligence Systems by Insurers. Insurers licensed in IA 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.
Technical 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.
Who is protected: Consumers, applicants, claimants, and policyholders in IA whose insurance decisions involve insurer AI systems
Who must comply: All insurers licensed to write business in IA (including health, life, P&C, and reinsurance lines)
Key facts
| Jurisdiction | IA |
|---|---|
| Level | State |
| Status | In effect |
| Protection strength | Limited protection |
| Effective date | 2024-11-07 |
| Enacted | 2024-11-07 |
| Citation | Iowa Insurance Division Bulletin 24-04 (2024-11-07) |
| Enforced by | IA Department / Division of Insurance |
| 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 |
| Last verified | 2026-07-26 |
| Official source | NAIC AI Model Bulletin Implementation Map (Apr. 1, 2026) ↗ |
Related insurance AI rules elsewhere
- Georgia SB 544 (health insurer AI) · Enacted (not yet in effect)
- Indiana HB 1271 (AI claims downcoding) · In effect
- Utah SB 319 (health insurer AI) · Enacted (not yet in effect)
- 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
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