NAIC AI Model Bulletin
Model bulletin adopted by the NAIC in December 2023 that establishes expectations for insurers' use of AI and external consumer data, including governance frameworks, accountability, documented AI inventories, and consumer-protection obligations. The bulletin is non-binding until a state issues a 'substantially similar' version; once it does, the bulletin becomes operationally binding in that state.
Not legal advice. This dataset is an aggregation of public regulatory text for informational purposes only. It is not legal advice and is not a substitute for counsel. Verify against the linked primary sources before relying on any row.
- Issuer
- National Association of Insurance Commissioners
- Sector
- Insurance
- Primary source
- Primary source ↗
- Row count
- 51 jurisdictions covered
Rows
| Jurisdiction | Status | Effective | Last verified | Summary | Source |
|---|---|---|---|---|---|
| Alaska | Pending adoption | no set effective date | 2026-07-08 | As of the most recent NAIC implementation map, Alaska has not yet adopted a substantially similar version of the NAIC AI Model Bulletin. The NAIC bulletin itself has no fixed effective date; state adoption triggers the obligations. The bulletin establishes expectations for insurers' use of AI / external consumer data, including governance, accountability, and documented AI system inventories. | Primary source ↗ |
| Alabama | Pending adoption | no set effective date | 2026-07-08 | Alabama has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. The bulletin remains a non-binding model until a state issues its own substantially similar guidance or regulation. | Primary source ↗ |
| Arkansas | Pending adoption | no set effective date | 2026-07-08 | Arkansas has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Arizona | Adopted | no set effective date | 2026-07-08 | Arizona is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Insurers operating in Arizona should treat the bulletin as the operational floor for AI governance, third-party data, and accountability expectations, layered onto Arizona Department of Insurance guidance. | Primary source ↗ |
| California | Adopted | no set effective date | 2026-07-08 | California is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. California also runs additional, more granular insurance AI guidance (CDI) and participates in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). Federal/state interaction with CFPB and California Privacy Agency rulemaking continues to evolve. | Primary source ↗ |
| Colorado | Adopted | no set effective date | 2026-07-08 | Colorado is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin, and also runs Colorado-specific insurance AI rules under the Division of Insurance that go further than the bulletin baseline. Colorado is the lead pilot state for the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Connecticut | Adopted | no set effective date | 2026-07-08 | Connecticut is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Connecticut is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Delaware | Adopted | no set effective date | 2026-07-08 | Delaware is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Florida | Adopted | no set effective date | 2026-07-08 | Florida is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Florida is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). Florida Office of Insurance Regulation may layer additional consumer-protection requirements on top of the bulletin. | Primary source ↗ |
| Georgia | Adopted | no set effective date | 2026-07-08 | Georgia is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Hawaii | Pending adoption | no set effective date | 2026-07-08 | Hawaii has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Iowa | Adopted | no set effective date | 2026-07-08 | Iowa is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Iowa is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Idaho | Pending adoption | no set effective date | 2026-07-08 | Idaho has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Illinois | Adopted | no set effective date | 2026-07-08 | Illinois is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Indiana | Adopted | no set effective date | 2026-07-08 | Indiana is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Kansas | Adopted | no set effective date | 2026-07-08 | Kansas is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Kentucky | Adopted | no set effective date | 2026-07-08 | Kentucky is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Louisiana | Adopted | no set effective date | 2026-07-08 | Louisiana is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Louisiana is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Massachusetts | Adopted | no set effective date | 2026-07-08 | Massachusetts is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Maryland | Adopted | no set effective date | 2026-07-08 | Maryland is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Maryland is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Maine | Pending adoption | no set effective date | 2026-07-08 | Maine has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Michigan | Adopted | no set effective date | 2026-07-08 | Michigan is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Minnesota | Adopted | no set effective date | 2026-07-08 | Minnesota is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Minnesota also runs its own consumer-protection framework (including a broader state AI law) that may layer additional requirements on insurance carriers operating in the state. | Primary source ↗ |
| Missouri | Pending adoption | no set effective date | 2026-07-08 | Missouri has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Mississippi | Pending adoption | no set effective date | 2026-07-08 | Mississippi has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Montana | Pending adoption | no set effective date | 2026-07-08 | Montana has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| North Carolina | Adopted | no set effective date | 2026-07-08 | North Carolina is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| North Dakota | Pending adoption | no set effective date | 2026-07-08 | North Dakota has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Nebraska | Adopted | no set effective date | 2026-07-08 | Nebraska is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| New Hampshire | Adopted | no set effective date | 2026-07-08 | New Hampshire is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| New Jersey | Adopted | no set effective date | 2026-07-08 | New Jersey is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. New Jersey also operates its own separate AI- and algorithmic-accountability framework (DOBI/DCA), and the state AG has been active on AI in insurance. | Primary source ↗ |
| New Mexico | Pending adoption | no set effective date | 2026-07-08 | New Mexico has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Nevada | Adopted | no set effective date | 2026-07-08 | Nevada is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| New York | Adopted | no set effective date | 2026-07-08 | New York is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin, but New York also operates one of the most prescriptive state-specific insurance AI frameworks in the US via NYDFS Circular Letter No. 7 (2024), which goes materially further than the NAIC baseline. Insurers should treat Circular Letter 7 as the operational floor in New York. | Primary source ↗ |
| Ohio | Adopted | no set effective date | 2026-07-08 | Ohio is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Oklahoma | Pending adoption | no set effective date | 2026-07-08 | Oklahoma has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Oregon | Adopted | no set effective date | 2026-07-08 | Oregon is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. | Primary source ↗ |
| Pennsylvania | Adopted | no set effective date | 2026-07-08 | Pennsylvania is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Pennsylvania is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Rhode Island | Adopted | no set effective date | 2026-07-08 | Rhode Island is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Rhode Island is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| South Carolina | Pending adoption | no set effective date | 2026-07-08 | South Carolina has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| South Dakota | Pending adoption | no set effective date | 2026-07-08 | South Dakota has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Tennessee | Adopted | no set effective date | 2026-07-08 | Tennessee is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Tennessee also passed the ELVIS Act / Tennessee Code Title 47 updates addressing AI in music/voice — not insurance-specific, but the state's broader AI posture is in motion. | Primary source ↗ |
| Texas | Adopted | no set effective date | 2026-07-08 | Texas is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Texas TDI has also issued its own AI-related guidance layered on top of the bulletin, particularly around underwriting and consumer-data use. | Primary source ↗ |
| Utah | Adopted | no set effective date | 2026-07-08 | Utah is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Utah also operates an AI-specific state law (the Utah AI Policy Act) that provides a disclosure-based framework — insurers should reconcile both layers. | Primary source ↗ |
| Virginia | Adopted | no set effective date | 2026-07-08 | Virginia is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Virginia is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| Vermont | Adopted | no set effective date | 2026-07-08 | Vermont is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Vermont is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). Vermont also operates a broader state AI law (H.114 / Act 132) that may layer additional obligations on insurance use cases. | Primary source ↗ |
| Washington | Adopted | no set effective date | 2026-07-08 | Washington is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Washington also operates the My Health My Data Act and has been active on algorithmic accountability via the Office of the Insurance Commissioner. | Primary source ↗ |
| Wisconsin | Adopted | no set effective date | 2026-07-08 | Wisconsin is listed by NAIC as having adopted a substantially similar version of the AI Model Bulletin. Wisconsin is also participating in the 12-state NAIC AI Systems Evaluation Tool pilot (Jan–Sep 2026). | Primary source ↗ |
| West Virginia | Pending adoption | no set effective date | 2026-07-08 | West Virginia has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| Wyoming | Pending adoption | no set effective date | 2026-07-08 | Wyoming has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. | Primary source ↗ |
| District of Columbia | Pending adoption | no set effective date | 2026-07-08 | The District of Columbia has not yet adopted a substantially similar version of the NAIC AI Model Bulletin per the NAIC's own implementation tracking. DC also operates a separate algorithmic accountability / AI bias law (the DC Stop Discrimination by Algorithms Act) that applies to insurance and other consumer-facing AI use. | Primary source ↗ |