Texas Will Analyze How P&C Insurers Use AI in Claims and Underwriting Before the Legislative Session

The Texas Department of Insurance has told the Governor it will produce an analysis of how property and casualty insurers use AI, built from its own examination data and from surveys of companies. The commitment appears in a September 14, 2026 letter from Commissioner of Insurance Amanda Crawford to Governor Greg Abbott, under a heading the department wrote as “Analysis of the use of AI in property and casualty (P&C) claims handling and underwriting.” One sentence carries it: “Using data from TDI exams and company surveys, TDI will produce a concise analysis of P&C insurers’ use of AI prior to the legislative session.”

The letter asks nothing of a carrier. It is a memorandum responding to a directive, it carries no bulletin or order number, and it sets no filing requirement and no compliance date. Crawford describes the document to the Governor as one that “outlines possible TDI administrative actions and identifies legislative changes for consideration during the upcoming session.” The verb on the AI item is “will produce.” The letter reports no survey already sent and no finding already reached.

Placement inside the letter does some work. TDI sorts its administrative actions into two sections, “A. Actions Directed by the Governor” and “B. Additional Administrative Actions.” The AI analysis is the first entry under B, ahead of P&C coverage overviews, a HelpInsure update, declarations pages, and four further items. Section A holds the items TDI attributes to the Governor’s instruction. The letter describes that directive as asking the department to identify more actions it can take to protect consumers and make property and casualty insurance more affordable for Texans, and bulletins on fortified roofs and on price optimization sit under it. By the department’s own sorting, looking at how carriers use AI is not among the actions Texas was directed to take.

On existing guidance the letter spends a single sentence: “Through a recently issued bulletin, TDI has made it clear to companies that any use of AI in making a consequential decision for policyholders must include a human review of the decision.” It does not number that bulletin. Then comes the turn: “But beyond this guidance, policymakers and consumers have an interest in knowing how companies are currently using AI for claim handling and underwriting decisions.”

That sentence points the other way from the bulletin. Guidance tells a company what is expected of it. An analysis asks what the company is actually doing, and this one is addressed past the carrier to the people who write statutes, with no rule attached and no date named beyond “prior to the legislative session.”

The inputs are the part a Texas P&C carrier can act on today. Exam data already exists, and it says whatever the company said to examiners about the systems it runs in claims and underwriting. Read that record again before a survey arrives asking the same question in a different form. The two answers will sit in the same file.