States are deciding, one at a time, how insurers may use artificial intelligence. The NAIC's Model Bulletin on the Use of Artificial Intelligence Systems by Insurers (adopted December 2023) is being taken up state by state, and Colorado has gone further with a binding statute and regulations. AI Insurance Watch tracks who has acted, when, and with a link to the official document for every entry. Free. Not legal advice.
If you write or advise on insurance in more than one state, the rulebook for AI use in underwriting, pricing and claims now changes every time a department of insurance issues a bulletin or a legislature passes a bill — and nobody sends you a notice.
Each row links to the state department of insurance's own bulletin or the legislature's own bill page, with the date. Where we could only confirm a status through a secondary source, we say so and name it rather than presenting it as primary.
A state we could not confirm from an official source is shown as unverified, never filled in with a guess. The tracker grows as each state is confirmed.
Regulation moves. Each entry shows when it was last checked, so you know how fresh it is.
Verified 2026-09-28 against state DOI bulletins, legislature bill pages, and the NAIC adoption reference list (status as of 2026-08-31). Rows marked State DOI / primary link the state's own document; rows marked NAIC adoption list are confirmed via the NAIC map (linked) where a state-hosted copy was not captured. Any action after 2026-08-31 may not yet appear.
| Adopted the NAIC AI Model Bulletin | 26 jurisdictions (25 states + DC) |
|---|---|
| Own AI-in-insurance instrument | 4 — California, Colorado, New York, Texas (Colorado the only binding statute + regulation) |
| No insurance-specific AI action | 21 jurisdictions |
| Undetermined jurisdictions | 0 — every jurisdiction resolved to adopted, own-instrument, or no-action. Sourcing basis differs by row: rows marked State DOI / primary link the state’s own document; rows marked NAIC adoption list rest on the NAIC reference list (linked) rather than a separately opened state document. |
| State | Instrument | Type | Date | Source | Basis |
|---|---|---|---|---|---|
| Colorado | SB21-169 — Restrict Insurers' Use of External Consumer Data (binding statute) | BINDING statute | signed 2021-07-06, eff. 2021-09-07 | source → | State DOI / primary |
| Colorado | 3 CCR 702-10 — CO DOI regulations implementing SB21-169 (governance + quantitative testing) | BINDING regulation | eff. 2023-11-13; amend. eff. 2025-10-15 | source → | NAIC adoption list |
| California | Bulletin 2022-5 — AI/Big-Data unfair-discrimination guidance | Guidance | 2022-06-30 | source → | NAIC adoption list |
| New York | Insurance Circular Letter No. 7 (2024) — AI & external data in underwriting/pricing | Guidance | 2024-07-11 | source → | State DOI / primary |
| Texas | Bulletin B-0003-26 — Use of Artificial Intelligence (current) | Guidance | 2026-06-12 | source → | State DOI / primary |
| Texas | Bulletin B-0036-20 (prior instrument) | Guidance (superseded) | 2020-09-30 | source → | NAIC adoption list |
The NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers was adopted by the NAIC on 2023-12-04 (NAIC topic page). These jurisdictions have issued it (or a close variant):
| State | Instrument | Date | Source | Basis |
|---|---|---|---|---|
| Alaska | Bulletin B 24-01 | 2024-02-01 | source → | NAIC adoption list |
| Arkansas | Bulletin 13-2024 | 2024-07-31 | source → | NAIC adoption list |
| Connecticut | Bulletin No. MC-25 | 2024-02-26 | source → | NAIC adoption list |
| Delaware | Domestic & Foreign Insurers Bulletin No. 148 | 2025-02-05 | source → | NAIC adoption list |
| District of Columbia | Bulletin 24-IB-002-05/21 | 2024-05-21 | source → | NAIC adoption list |
| Hawaii | Insurance Commissioner Memorandum No. 2025-13A | 2025-12-10 | source → | NAIC adoption list |
| Illinois | Company Bulletin 2024-08 | 2024-03-13 | source → | NAIC adoption list |
| Iowa | Insurance Division Bulletin 24-04 | 2024-11-07 | source → | NAIC adoption list |
| Kentucky | Bulletin No. 2024-02 | 2024-04-16 | source → | NAIC adoption list |
| Maryland | Bulletin No. 24-11 | 2024-04-22 | source → | State DOI / primary |
| Massachusetts | Bulletin No. 2024-10 | 2024-12-09 | source → | Official source |
| Michigan | Bulletin 2024-20-INS | 2024-08-07 | source → | Official source |
| Mississippi | Bulletin 2026-9 | 2026-07-22 | source → | NAIC adoption list |
| Nebraska | Insurance Guidance Document No. IGD-H1 | 2024-06-11 | source → | State DOI / primary |
| Nevada | Bulletin 24-001 | 2024-02-23 | source → | Official source |
| New Hampshire | Bulletin Docket #INS 24-011-AB | 2024-02-20 | source → | NAIC adoption list |
| New Jersey | Insurance Bulletin No. 25-03 | 2025-02-11 | source → | State DOI / primary |
| North Carolina | Bulletin No. 24-B-19 | 2024-12-18 | source → | State DOI / primary |
| Oklahoma | Bulletin No. 2024-11 | 2024-11-14 | source → | State DOI / primary |
| Pennsylvania | Insurance Notice 2024-04, 54 Pa.B. 1910 | 2024-04-06 | source → | State DOI / primary |
| Rhode Island | Insurance Bulletin No. 2024-03 | 2024-03-15 | source → | Official source |
| Vermont | Insurance Bulletin No. 229 | 2024-03-12 | source → | NAIC adoption list |
| Virginia | Administrative Letter 2024-01 | 2024-07-22 | source → | NAIC adoption list |
| Washington | Technical Assistance Advisory 2024-02 | 2024-04-22 | source → | NAIC adoption list |
| West Virginia | Insurance Bulletin No. 24-06 | 2024-08-09 | source → | NAIC adoption list |
| Wisconsin | Insurance Bulletin (no. not stated in NAIC list) | 2025-03-18 | source → | NAIC adoption list |
Alabama, Arizona, Florida, Georgia, Idaho, Indiana, Kansas, Louisiana, Maine, Minnesota, Missouri, Montana, New Mexico, North Dakota, Ohio, Oregon, South Carolina, South Dakota, Tennessee, Utah, Wyoming.
General AI laws that are not insurance-specific are excluded here — e.g. Utah SB 149 (AI Policy Act, 2024), Texas TRAIGA/HB 149 (2026), and Virginia's vetoed HB 2094 — because they create no binding AI-in-insurance obligation.
| Item | Detail | Date | Source |
|---|---|---|---|
| NAIC Model Bulletin | Model Bulletin on the Use of Artificial Intelligence Systems by Insurers | adopted 2023-12-04 | NAIC → |
| NCOIL | No dedicated AI-in-insurance model act in its Model Laws Library | — | NCOIL → |
| EU AI Act (international context) | Regulation (EU) 2024/1689 | in force 2024-08-01; phased from 2026-08-02 | EUR-Lex → |
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What this is. A tracked, source-cited record of publicly available state action on the use of AI in insurance. What this is not. It is not legal advice, not a compliance determination, and not a law firm. It does not interpret statutes or bulletins, does not tell you whether you are compliant, and is not a substitute for reading the official document (linked on every row) or consulting counsel. Dates and statuses are as of the last-verified date shown. If you spot an error, email carey@kcalbin.com.
How this tracker is updated. The official state sources we can reach are checked automatically every day for changes; any detected change is flagged to a human, verified against the primary document, and only then is a row and its verified date updated — nothing is published automatically from an automated check. A few sources (the NAIC list, and the New York, Colorado, Massachusetts and Rhode Island pages) block automated access, so those are re-checked by hand periodically. This is a verified snapshot, not a real-time feed.