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Be board-ready on AI-insurance regulation without doing the reading

One verified, always-current view of how every state and the federal government govern insurers’ use of AI. Each item links its primary source with a plain-English summary.

Live now: the NAIC AI Systems Evaluation Tool pilot is running in 12 states through September 2026. The moment AI-governance guidance becomes a regulator exam.

Alabama: No state action yetAlaska: Adopted the NAIC Model BulletinArizona: No state action yetColorado: Has its own state ruleFlorida: No state action yetGeorgia: No state action yetIndiana: No state action yetKansas: No state action yetMaine: No state action yetMassachusetts: Adopted the NAIC Model BulletinMinnesota: No state action yetNew Jersey: Adopted the NAIC Model BulletinNorth Carolina: Adopted the NAIC Model BulletinNorth Dakota: No state action yetOklahoma: Adopted the NAIC Model BulletinPennsylvania: Adopted the NAIC Model BulletinSouth Dakota: No state action yetTexas: Has its own state ruleWyoming: No state action yetConnecticut: Adopted the NAIC Model BulletinMissouri: No state action yetWest Virginia: Adopted the NAIC Model BulletinIllinois: Adopted the NAIC Model BulletinNew Mexico: No state action yetArkansas: Adopted the NAIC Model BulletinCalifornia: Has its own state ruleDelaware: Adopted the NAIC Model BulletinDistrict of Columbia: Adopted the NAIC Model BulletinHawaii: Adopted the NAIC Model BulletinIowa: Adopted the NAIC Model BulletinKentucky: Adopted the NAIC Model BulletinMaryland: Adopted the NAIC Model BulletinMichigan: Adopted the NAIC Model BulletinMississippi: No state action yetMontana: No state action yetNew Hampshire: Adopted the NAIC Model BulletinNew York: Has its own state ruleOhio: No state action yetOregon: No state action yetTennessee: No state action yetUtah: No state action yetVirginia: Adopted the NAIC Model BulletinWashington: Adopted the NAIC Model BulletinWisconsin: Adopted the NAIC Model BulletinNebraska: Adopted the NAIC Model BulletinSouth Carolina: No state action yetIdaho: No state action yetNevada: Adopted the NAIC Model BulletinVermont: Adopted the NAIC Model BulletinLouisiana: No state action yetRhode Island: Adopted the NAIC Model BulletinCOTXCANY
Adopted the NAIC Model Bulletin25Has its own state rule4No state action yet22Source: NAIC implementation map · as of 2026-04-01

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What changed

6 recent updates, newest first
  1. Pilot· United States (Federal)

    NAIC AI Systems Evaluation Tool pilot goes live in 12 states

    The NAIC's AI Systems Evaluation Tool entered a 12-state pilot running March to September 2026. It gives regulators a structured way to examine, in a market-conduct or financial exam, how extensively an insurer uses AI and how it governs those systems. This is the point where AI-governance guidance becomes an examination instrument.

    NAIC AI Systems Evaluation Tool (2026 pilot)Read the primary source →
  2. Adoption· Hawaii

    Hawaii adopts the NAIC AI Model Bulletin

    Hawaii adopted the NAIC Model Bulletin on the Use of AI Systems by Insurers through Commissioner Memo No. 2025-13A, joining the states that expect insurers to maintain a written AI governance program. Verify the memo's scope against the primary source.

    Commissioner Memo No. 2025-13ARead the primary source →
  3. Amendment· Colorado

    Colorado's amended Regulation 10-1-1 takes effect

    Colorado's amended Regulation 10-1-1 (3 CCR 702-10), implementing SB 21-169, took effect October 15, 2025. It sets the governance and risk-management framework for insurers' use of external consumer data, algorithms, and predictive models, and reaches life, private passenger auto, and health benefit plan insurers. Colorado pairs the framework with quantitative testing, which distinguishes it from principle-based states.

    Colorado Reg 10-1-1 (3 CCR 702-10)Read the primary source →
  4. Adoption· Wisconsin

    Wisconsin adopts the NAIC AI Model Bulletin

    Wisconsin adopted the NAIC Model Bulletin on the Use of AI Systems by Insurers, extending the written-AI-program expectation to insurers operating in the state. Verify the bulletin's specifics against the primary source.

    Wisconsin Insurance BulletinRead the primary source →
  5. Adoption· New Jersey

    New Jersey adopts the NAIC AI Model Bulletin

    New Jersey adopted the NAIC Model Bulletin on the Use of AI Systems by Insurers via Bulletin No. 25-03, joining the states that expect a written AI governance program. Verify against the primary source.

    Bulletin No. 25-03Read the primary source →
  6. Adoption· Delaware

    Delaware adopts the NAIC AI Model Bulletin

    Delaware adopted the NAIC Model Bulletin on the Use of AI Systems by Insurers via Bulletin No. 148, holding insurers to a written AI governance program. Verify against the primary source.

The instruments that set the bar

Each one in plain English: what it requires, who it reaches, and the primary source.

Colorado Division of Insurance· 2025-10-15

Colorado SB 21-169 and Regulation 10-1-1 (3 CCR 702-10): Governance and Risk Management for Insurers' Use of External Consumer Data, Algorithms, and Predictive Models

Colorado is the quantitative-testing outlier. SB 21-169 prohibits insurers from using external consumer data, algorithms, and predictive models in a way that unfairly discriminates against protected classes, and directs the Division of Insurance to require testing. Regulation 10-1-1 (3 CCR 702-10) builds the governance and risk-management framework that implements it; the amended regulation took effect October 15, 2025 and reaches life, private passenger auto, and health benefit plan insurers using such models.

Read the full breakdown →
New York Department of Financial Services· 2024-07-11

New York DFS Circular Letter No. 7 (2024): Use of Artificial Intelligence Systems and External Consumer Data in Insurance Underwriting and Pricing

New York is the most prescriptive. DFS Circular Letter No. 7 (July 11, 2024) tells insurers how it expects them to manage AI systems and external consumer data in underwriting and pricing: test for unfair or unlawful discrimination using multiple statistical metrics, follow a three-step disparate-impact analysis, search annually for less-discriminatory alternatives, and retain full responsibility for third-party tools. DFS also expects insurers to disclose the use of AI when adverse decisions are made.

Read the full breakdown →
NAIC· 2023-12-04

NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers

The NAIC's model framework setting out how it expects insurers to govern their use of AI. It sets expectations rather than a checklist: insurers are expected to maintain a written AI program covering governance, risk management, internal audit, consumer protection, and oversight of third-party AI vendors. It is principle-based, so compliance is judged on reasonableness, not a fixed standard. States adopt it through their own bulletins; roughly half had adopted it as of early 2025.

Read the full breakdown →
NAIC Big Data and Artificial Intelligence (H) Working Group

NAIC AI Systems Evaluation Tool (2026 Pilot)

This is the moment guidance becomes examination. The NAIC AI Systems Evaluation Tool gives regulators a structured way to gather, in a market-conduct or financial-exam context, how extensively an insurer uses AI, its governance and risk-mitigation practices, detail on high-risk AI models, and the data feeding those systems. A 12-state pilot runs March to September 2026, with adoption targeted at the NAIC Fall National Meeting in 2026. It puts a live calendar date on AI-governance exam risk.

Read the full breakdown →
U.S. federal government

The federal picture: AI policy, preemption, and US insurers

There is no single federal law regulating how insurers use AI. Under the McCarran-Ferguson Act, insurance is regulated by the states, and federal law does not displace state insurance regulation unless Congress acts specifically on the business of insurance. Federal AI policy is currently deregulatory, and the question of who governs AI, the federal government or the states, is unresolved: a proposed ten-year ban on state AI laws was struck from the 2025 budget bill, and a December 2025 executive order directs federal agencies to challenge conflicting state AI laws. Neither targets insurance. For insurers, the binding rules today remain state-level. As of June 2026.

Read the full breakdown →

The weekly regulation digest

Every new state and federal move on AI-in-insurance, in one short email a week. No noise, primary sources only.

MandateMap stages primary regulatory information and does not provide legal or compliance advice. Verify against the linked primary source and consult qualified counsel.