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)
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.
Technical 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.
Who is protected: Insurance policyholders and applicants in adopting states, against discriminatory AI in underwriting, claims, and marketing
Who must comply: Insurers in states that have adopted the bulletin via a state department of insurance bulletin or regulation
Key facts
| Jurisdiction | United States |
|---|---|
| Level | Federal |
| Status | In effect |
| Protection strength | Limited protection |
| Effective date | 2023-12-04 |
| Enacted | 2023-12-04 |
| Citation | NAIC Model Bulletin: Use of AI Systems (Dec. 4, 2023); NAIC Impl. Map (Apr. 2025) |
| Enforced by | State insurance commissioners in 26+ adopting states; market conduct examinations |
| Private right of action | No — agency enforcement only |
| Penalties | Varies by state; typically insurance regulatory sanctions for unfair trade practices or market conduct violations |
| Topics | insurance AI · automated decision-making · AI disclosure and transparency |
| Last verified | 2026-08-09 |
| Official source | Artificial Intelligence | Insurance Topics — NAIC ↗ |
More AI rules in United States
- Trump AI Innovation & Security EO (June 2026) · In effect
- FERC order directing PJM and other grid operators to reform · Enacted (not yet in effect)
- Chatrie v. United States (Fourth Amendment protection for lo · Blocked / in litigation
- Kids Internet and Digital Safety Act (KIDS Act) (H.R. 7757) · Proposed / pending
- NAIC AI Evaluation Tool Pilot (12 states, 2026) · Proposed / pending
- FTC Proposed Policy Statement — AI Accuracy (July 2026) · Proposed / pending
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
- AZ HB 2175 (AI Insurance Denial — Physician Review) · In effect
- TX TDI Bulletin B-0003-26 (AI in insurance) · In effect
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