NAIC AI Model Bulletin (Insurance)

NAIC Model Bulletin on Use of AI Systems by Insurers (Dec. 2023) — 26+ State Adoption
United States · NAIC Model Bulletin: Use of AI Systems (Dec. 4, 2023); NAIC Impl. Map (Apr. 2025)

Status
In effect
Took effect
December 4, 2023
Applies to
Insurers in states that have adopted the bulletin via a state department of insurance bulletin or regulation
Enforced by
State insurance commissioners in 26+ adopting states; market conduct examinations

The National Association of Insurance Commissioners adopted a Model Bulletin in December 2023 directing insurers to govern their AI responsibly — documenting AI systems, testing for bias, and overseeing third-party AI vendors. As of early 2026, over half of U.S. states and D.C. have adopted the bulletin through their own state insurance departments, making it the broadest AI governance standard in the insurance sector. It is not a federal law and has no penalties on its own, but state commissioners use it as a market-conduct examination standard.

Who is protected: Insurance policyholders and applicants in adopting states, against discriminatory AI in underwriting, claims, and marketing

Legal detail

NAIC Model Bulletin: Use of AI Systems (adopted Dec. 4, 2023) requires insurers in adopting states to maintain a written responsible-AI program, document and test AI systems (including for unfair discrimination), govern third-party AI vendors, and report AI system outcomes. As of March 2026 NAIC AI Issue Brief, 26+ jurisdictions issued their own state DOI bulletins adopting it. The NAIC AI Systems Evaluation Tool was in a 12-state pilot with full NAIC adoption expected at the Fall 2026 National Meeting.

Key facts

JurisdictionUnited States
LevelFederal
StrengthLimited
EnactedDecember 4, 2023
CitationNAIC Model Bulletin: Use of AI Systems (Dec. 4, 2023); NAIC Impl. Map (Apr. 2025)
Private right of actionNo, agency enforcement only
PenaltiesVaries by state; typically insurance regulatory sanctions for unfair trade practices or market conduct violations
Topicsinsurance AI · automated decision-making · AI disclosure and transparency
Agency pageArtificial Intelligence | Insurance Topics — NAIC

More AI rules in United States

Related insurance AI rules elsewhere

See something wrong or out of date? Submit a correction. Every entry must carry a verifiable source.