Illinois DOI Company Bulletin 2024-08 — Use of AI Systems by Insurers (NAIC Model Bulletin adoption)
IL · Illinois DOI Company Bulletin 2024-08 (2024-03-13)
The IL Department of Insurance adopted the NAIC Model Bulletin on Use of Artificial Intelligence Systems by Insurers. Insurers licensed in IL 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 IL whose insurance decisions involve insurer AI systems
Who must comply: All insurers licensed to write business in IL (including health, life, P&C, and reinsurance lines)
Key facts
| Jurisdiction | IL |
|---|---|
| Level | State |
| Status | In effect |
| Protection strength | Limited protection |
| Effective date | 2024-03-13 |
| Enacted | 2024-03-13 |
| Citation | Illinois DOI Company Bulletin 2024-08 (2024-03-13) |
| Enforced by | IL 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 | IL DOI Illinois DOI Company Bulletin 2024-08 (PDF) ↗ |
More AI rules in IL
- IL Bar AI Standing Committee · In effect
- IL Digital Voice/Likeness Act · In effect
- IL WOPR (AI therapy ban) · In effect
- IL EO 2024-01 · In effect
- IL AI Video Interview Act (2019, first-in-nation) · In effect
- IL BIPA (2008, first-in-nation biometric law) · In effect
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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