NJ DOI AI Bulletin
New Jersey DOBI Insurance Bulletin 25-03 — Use of AI Systems by Insurers (NAIC Model Bulletin adoption)
NJ · New Jersey DOBI Insurance Bulletin 25-03 (2025-02-11)
- Status
- In effect
- Took effect
- February 11, 2025
- Applies to
- All insurers licensed to write business in NJ (including health, life, P&C, and reinsurance lines)
- Enforced by
- NJ Department / Division of Insurance
The NJ Department of Insurance adopted the NAIC Model Bulletin on Use of Artificial Intelligence Systems by Insurers. Insurers licensed in NJ 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 NJ 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 | NJ |
|---|---|
| Level | State |
| Strength | Limited |
| Enacted | February 11, 2025 |
| Citation | New Jersey DOBI Insurance Bulletin 25-03 (2025-02-11) |
| 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) |
More AI rules in NJ
- NJ Kids Code Act A4015 (signed Aug 11, 2026; effective Sept 1, 2027) · Enacted (not yet in effect)
- NJ Fair Price Protection Act, P.L.2026, c.55 (2026) · Enacted (not yet in effect)
- NJ AG Platkin / DCR · In effect
- NJ Supreme Court GenAI Notice · In effect
- NJ EO 346 (AI Task Force) · In effect
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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