29 jurisdictions, 27 states plus DC and Puerto Rico, have adopted the NAIC’s model bulletin on how insurers use AI, according to the NAIC’s map dated 8 October 2026. Four more states set their own rules.
Each entry links to the state’s own document where we could find it. Checked 22 October 2026. Download as CSV.
The bottom row shows the territories: Puerto Rico, Guam, the US Virgin Islands, American Samoa and the Northern Mariana Islands.
2026 is the year so far.
Insurers should keep a written program for responsible use of AI systems, scaled to the risk to consumers and covering the whole life of each system, with clear accountability, risk controls, internal audit, and testing of predictive models for errors, bias and performance decay. Insurers stay responsible for AI they get from outside vendors, so they should vet those vendors, build audit and cooperation terms into contracts, and keep AI records ready for regulators who examine or investigate them. Read the model bulletin.
It is a reminder of existing law, not a new law: decisions made or supported by AI must still meet the rules on unfair trade practices and unfair discrimination. Each state issues its own version, and the names vary: bulletin, memorandum, advisory, notice or ruling letter.
| State | Status | Document | Issued | Notes |
|---|---|---|---|---|
| Alabama | Not on the NAIC’s list | — | — | — |
| Alaska | Adopted the bulletin | B 24-01 | 1 Feb 2024 | The state’s PDF could not be read as text, so the number and date here are the NAIC’s. Not confirmed on the state’s site. |
| American Samoa | Not on the NAIC’s list | — | — | — |
| Arizona | Not on the NAIC’s list | — | — | — |
| Arkansas | Adopted the bulletin | 13-2024Use of Artificial Intelligence Systems in Insurance | 31 Jul 2024 | — |
| California | Own AI rules | Bulletin 2022-5 | 30 Jun 2022 | — |
| Colorado | Own AI rules | Regulation 10-1-1 (3 CCR 702-10) | 14 Nov 2023 | — |
| Connecticut | Adopted the bulletin | MC-25Use of Artificial Intelligence Systems by Insurers | 26 Feb 2024 | Adds an annual AI certification for Connecticut-domiciled insurers and asks for board and senior-management oversight of AI in the annual corporate governance disclosure. |
| Delaware | Adopted the bulletin | Domestic and Foreign Bulletin No. 148The Use of Artificial Intelligence Systems in Insurance | 5 Feb 2025 | Effective immediately |
| District of Columbia | Adopted the bulletin | 24-IB-002-05/21The Use of Artificial Intelligence Systems in Insurance | 21 May 2024 | — |
| Florida | Not on the NAIC’s list | — | — | — |
| Georgia | Not on the NAIC’s list | — | — | — |
| Guam | Not on the NAIC’s list | — | — | — |
| Hawaii | Adopted the bulletin | Commissioner’s Memorandum 2025-13ACommissioner’s memorandum: The Use of Artificial Intelligence Systems in Insurance | 10 Dec 2025 | The state’s page shows it posted on 11 December 2025; the date here is the NAIC’s. |
| Idaho | Not on the NAIC’s list | — | — | — |
| Illinois | Adopted the bulletin | Company Bulletin 2024-08The Use of Artificial Intelligence Systems in Insurance | 13 Mar 2024 | — |
| Indiana | Not on the NAIC’s list | — | — | — |
| Iowa | Adopted the bulletin | 24-04The Use of Artificial Intelligence Systems in Insurance | 7 Nov 2024 | — |
| Kansas | Not on the NAIC’s list | — | — | — |
| Kentucky | Adopted the bulletin | 2024-02Use of Artificial Intelligence Systems in the Business of Insurance | 16 Apr 2024 | The state’s PDF could not be read as text, so the number and date here are the NAIC’s. Not confirmed on the state’s site. |
| Louisiana | Not on the NAIC’s list | — | — | — |
| Maine | Not on the NAIC’s list | — | — | — |
| Maryland | Adopted the bulletin | 24-11The Use of Artificial Intelligence Systems in Insurance | 22 Apr 2024 | — |
| Massachusetts | Adopted the bulletin | 2024-10The Use of Artificial Intelligence Systems in Insurance | 9 Dec 2024 | — |
| Michigan | Adopted the bulletin | 2024-20-INSUse of Artificial Intelligence Systems by Insurers | 7 Aug 2024 | — |
| Minnesota | Not on the NAIC’s list | — | — | — |
| Mississippi | Adopted the bulletin | 2026-9Use of Artificial Intelligence Systems by Insurers | 22 Jul 2026 | — |
| Missouri | Not on the NAIC’s list | — | — | — |
| Montana | Not on the NAIC’s list | — | — | — |
| Nebraska | Adopted the bulletin | Insurance Guidance Document IGD-H1Guidance document: Use of Artificial Intelligence by Insurers | 11 Jun 2024 | Issued as a guidance document. A footnote refers to the model bulletin. |
| Nevada | Adopted the bulletin | 24-001Use of Artificial Intelligence Systems by Insurers | 23 Feb 2024 | Linked copy is held by the Nevada State Library. |
| New Hampshire | Adopted the bulletin | Docket # INS 24-011-ABUse of Artificial Intelligence Systems by Insurers | 20 Feb 2024 | — |
| New Jersey | Adopted the bulletin | 25-03The Use of Artificial Intelligence Systems in Insurance | 11 Feb 2025 | — |
| New Mexico | Not on the NAIC’s list | — | — | — |
| New York | Own AI rules | Insurance Circular Letter No. 7 (2024) | 11 Jul 2024 | — |
| North Carolina | Adopted the bulletin | 24-B-19The Use of Artificial Intelligence Systems in Insurance | 18 Dec 2024 | — |
| North Dakota | Adopted the bulletin | 2026-2Use of Algorithms, Predictive Models, and Artificial Intelligence in Insurance | 5 Oct 2026 | Ties its expectations to North Dakota statutes and says a written AI program is encouraged rather than required; AI use can be investigated either way. In effect until rescinded |
| Northern Mariana Islands | Not on the NAIC’s list | — | — | — |
| Ohio | Not on the NAIC’s list | — | — | — |
| Oklahoma | Adopted the bulletin | 2024-11Use of Artificial Intelligence Systems in Insurance | 14 Nov 2024 | — |
| Oregon | Not on the NAIC’s list | — | — | — |
| Pennsylvania | Adopted the bulletin | Insurance Notice 2024-04 (54 Pa.B. 1910)Notice in the Pennsylvania Bulletin | 6 Apr 2024 | The Insurance Department’s release says the notice is based on the NAIC model bulletin; the notice itself is in the Pennsylvania Bulletin. |
| Puerto Rico | Adopted the bulletin | CN-2026-382-DRuling letter: Use of Artificial Intelligence Systems in the Insurance Industry in Accordance with the NAIC Model Bulletin | 11 Jun 2026 | Applies the model’s principles only where consistent with the Puerto Rico Insurance Code, ties AI use to its cybersecurity rule, and says it creates no new separate obligations. Effective on issue |
| Rhode Island | Adopted the bulletin | Insurance Bulletin 2024-03Use of Artificial Intelligence Systems by Insurers | 15 Mar 2024 | — |
| South Carolina | Adopted the bulletin | 2026-07 | 24 Sep 2026 | Listed by the NAIC. We could not find the bulletin on the South Carolina Department of Insurance site. Not confirmed on the state’s site. |
| South Dakota | Not on the NAIC’s list | — | — | — |
| Tennessee | Not on the NAIC’s list | — | — | — |
| Texas | Own AI rules | Commissioner's Bulletin B-0003-26 | 12 Jun 2026 | — |
| U.S. Virgin Islands | Not on the NAIC’s list | — | — | — |
| Utah | Not on the NAIC’s list | — | — | — |
| Vermont | Adopted the bulletin | Insurance Bulletin No. 229The Use of Artificial Intelligence Systems in Insurance | 12 Mar 2024 | — |
| Virginia | Adopted the bulletin | Administrative Letter 2024-01Administrative letter: The Use of Artificial Intelligence Systems | 22 Jul 2024 | — |
| Washington | Adopted the bulletin | Technical Assistance Advisory 2024-02Technical assistance advisory: The Use of Artificial Intelligence Systems in Insurance | 22 Apr 2024 | A footnote says it is based on a model bulletin adopted by the NAIC. |
| West Virginia | Adopted the bulletin | Insurance Bulletin No. 24-06Artificial Intelligence Systems | 9 Aug 2024 | — |
| Wisconsin | Adopted the bulletin | BulletinThe Use of Artificial Intelligence Systems in Insurance | 18 Mar 2025 | — |
| Wyoming | Not on the NAIC’s list | — | — | — |
Tells insurers to make sure the data, algorithms and AI they use in marketing, rating, underwriting and claims do not produce biased or unfairly discriminatory results. It predates the NAIC model.
Source: Bulletin 2022-5; related official page.
Requires a governance and risk-management framework for insurers that use external consumer data, algorithms and predictive models, so they can test for unfair discrimination. It first applied to life insurers from 14 November 2023 and was extended to private passenger auto and health benefit plan insurers from 15 October 2025.
The NAIC’s map gives 13 November 2023 as the first effective date; Colorado’s regulation says 14 November 2023.
Source: Regulation 10-1-1 (3 CCR 702-10); related official page.
Says insurers should not use AI or external consumer data in underwriting or pricing unless they can show it is not unfairly or unlawfully discriminatory, with governance, testing and documentation behind it. It covers underwriting and pricing only, and says it borrows a vendor clause from the NAIC model.
Sets expectations for AI governance, risk controls, bias testing, records the Texas Department of Insurance can request, and human review of consequential decisions, built on Texas law. The NAIC's map, dated 8 October 2026, still lists only Texas's 2020 bulletin on third-party data.
Source: Commissioner's Bulletin B-0003-26; related official page.
This tracker is about how insurers use AI. For insurance that covers a company’s own AI risks, see who insures AI and the AI exclusions tracker. Spot a new bulletin? Email us.
It is a model the National Association of Insurance Commissioners adopted on 4 December 2023 for state insurance regulators to issue. It reminds insurers that decisions made or supported by AI must comply with existing insurance laws, including those on unfair trade practices and unfair discrimination, and says insurers are expected to keep a written program for using AI responsibly.
29 jurisdictions are on the NAIC’s list of adopters as of 8 October 2026: 27 states plus the District of Columbia and Puerto Rico. The NAIC’s April 2026 version of the map listed 25.
No. It describes itself as a reminder of existing obligations and a statement of what the regulator expects, and says it does not prescribe specific practices. Each state issues it under its own authority, sometimes with changes.
California, Colorado, New York and Texas. Colorado has a regulation under SB21-169, New York has Circular Letter No. 7 (2024), California has Bulletin 2022-5 and Texas issued its own AI bulletin in June 2026.
Not directly. The bulletin is about how insurers use AI in their own decisions, such as pricing, underwriting and claims. Cover for a company’s own AI risks is tracked in our register of who insures AI.
