InsureAI Wire

State AI Regulation Tracker

NAIC AI Model Bulletin Adoption by State

Verified Sep 4, 2026 NAIC status map: Aug 6, 2026 ↗
Latest adoption: Hawaii · Dec 10, 2025

How many states have adopted the NAIC AI model bulletin?

24 states and the District of Columbia have adopted the NAIC AI model bulletin, 25 of the 51 U.S. insurance jurisdictions, according to the NAIC status map dated Aug 6, 2026.

Adoption map

NAIC AI Model Bulletin adoption by U.S. jurisdiction as of Aug 2026: 25 adopted the bulletin, 4 regulate insurer AI under their own frameworks, and 22 have issued no AI guidance for insurers. The table below lists every jurisdiction with its instrument, date and source. NH VT MA RI CT NJ DE MD DC ADOPTED NAIC BULLETIN INDEPENDENT FRAMEWORK NO GUIDANCE ISSUED
  • Adopted
  • Own rules
  • None issued
FIG. 1: MODEL BULLETIN ADOPTION BY JURISDICTION SOURCE: NAIC implementation map, Aug 6, 2026

Where we read the state's own text

The NAIC map above tells you whether a jurisdiction has acted. These 4 pages tell you what its text actually says that the model bulletin does not, with the evidence on both sides, and the filings and deadlines that follow.

California Own rules 6 differences · 2 standing obligations Colorado Own rules 9 differences · 5 standing obligations New York Own rules 9 differences · 6 standing obligations Texas Own rules 6 differences · 2 standing obligations

Free weekly briefing

Changes to this table go out in the weekly briefing

Jurisdiction details

51 of 51
Insurance AI regulatory status, source instrument, and effective date for every U.S. jurisdiction
Jurisdiction Status
Alabama AL None issued
Alaska AK Bulletin B 24-01 Feb 1, 2024 Adopted
Arizona AZ None issued
Arkansas AR Bulletin 13-2024 Jul 31, 2024 Adopted
California → CA Bulletin 2022-5 Jun 30, 2022 Own rules
Colorado → CO 3 CCR 702-10 (Reg 10-1-1) Eff. Nov 14, 2023 Own rules
Connecticut CT Bulletin No. MC-25 Feb 26, 2024 Adopted
Delaware DE Domestic and Foreign Bulletin No. 148 Feb 5, 2025 Adopted
District of Columbia DC Bulletin 24-IB-002-05/21 May 21, 2024 Adopted
Florida FL None issued
Georgia GA None issued
Hawaii HI Insurance Commissioner Memorandum No. 2025-13A Dec 10, 2025 Adopted
Idaho ID None issued
Illinois IL Company Bulletin 2024-08 Mar 13, 2024 Adopted
Indiana IN None issued
Iowa IA Insurance Division Bulletin 24-04 Nov 7, 2024 Adopted
Kansas KS None issued
Kentucky KY Bulletin No. 2024-02 Apr 16, 2024 Adopted
Louisiana LA None issued
Maine ME None issued
Maryland MD Bulletin No. 24-11 Apr 22, 2024 Adopted
Massachusetts MA Bulletin No. 2024-10 Dec 9, 2024 Adopted
Michigan MI Bulletin 2024-20-INS Aug 7, 2024 Adopted
Minnesota MN None issued
Mississippi MS None issued
Missouri MO None issued
Montana MT None issued
Nebraska NE Insurance Guidance Document No. IGD-H1 Jun 11, 2024 Adopted
Nevada NV Bulletin 24-001 Feb 23, 2024 Adopted
New Hampshire NH Bulletin Docket #INS 24-011-AB Feb 20, 2024 Adopted
New Jersey NJ Insurance Bulletin No. 25-03 Feb 11, 2025 Adopted
New Mexico NM None issued
New York → NY Insurance Circular Letter No. 7 (2024) Jul 11, 2024 Own rules
North Carolina NC Bulletin No. 24-B-19 Dec 18, 2024 Adopted
North Dakota ND None issued
Ohio OH None issued
Oklahoma OK Bulletin No. 2024-11 Nov 14, 2024 Adopted
Oregon OR None issued
Pennsylvania PA Insurance Notice 2024-04 (54 Pa.B. 1910) Apr 6, 2024 Adopted
Rhode Island RI Insurance Bulletin No. 2024-03 Mar 15, 2024 Adopted
South Carolina SC None issued
South Dakota SD None issued
Tennessee TN None issued
Texas → TX Bulletin B-0036-20 Sep 30, 2020 Own rules
Utah UT None issued
Vermont VT Insurance Bulletin No. 229 Mar 12, 2024 Adopted
Virginia VA Administrative Letter 2024-01 Jul 22, 2024 Adopted
Washington WA Technical Assistance Advisory 2024-02 Apr 22, 2024 Adopted
West Virginia WV Insurance Bulletin No. 24-06 Aug 9, 2024 Adopted
Wisconsin WI Insurance Bulletin (Mar. 18, 2025) Mar 18, 2025 Adopted
Wyoming WY None issued

A row without a link has not been read at that depth.

Reporting by jurisdiction

16 jurisdictions · 26 selected items · Reviewed Aug 24, 2026

Browse reporting and analysis selected for 16 jurisdictions. Choose a jurisdiction to see why each piece is relevant.

Arizona AZ

1 selected item

California CA

3 selected items Open state analysis →

Colorado CO

3 selected items Open state analysis →

Georgia GA

1 selected item

Illinois IL

1 selected item

Indiana IN

1 selected item

Kentucky KY

1 selected item

Louisiana LA

1 selected item

Maryland MD

1 selected item

Minnesota MN

3 selected items

Nebraska NE

1 selected item

New York NY

3 selected items Open state analysis →

Pennsylvania PA

1 selected item

Rhode Island RI

1 selected item

Texas TX

3 selected items Open state analysis →

Utah UT

1 selected item

Change log

Last status change: Dec 10, 2025 · 268 days ago

  1. Review Weekly review found no change. The NAIC legal adoption map was downloaded again and is byte-for-byte the file reviewed a week earlier: 416,659 bytes, an August 6, 2026 status date, and a Last-Modified header of August 6, 2026. Its page 2 reference list was compared line by line against all 51 tracked rows and matched on every instrument number and adoption date, still 25 adopting jurisdictions and the four independent-framework states. Five source links were spot-checked at their own departments (Delaware, Hawaii, Iowa, Nebraska, New Jersey) and all five resolved and matched on number and date.

    Primary source ↗

  2. Review Weekly review found no change. Both NAIC adoption maps were downloaded again: the legal adoption map still carries an August 6, 2026 status date at the same 416,659 bytes, and the older committee map still stops at April 1, 2026. Its page 2 reference list matched all 51 tracked rows line for line, still 25 adopting jurisdictions and the four independent-framework states, with every instrument number and adoption date unchanged. Five source links were spot-checked at their own departments (Arkansas, Maryland, Michigan, Rhode Island, Vermont) and all five resolved and matched on number and date.

    Primary source ↗

  3. Review The NAIC reissued its adoption map with an August 6, 2026 status date. Its page 2 reference list still names the same 25 adopting jurisdictions and four independent-framework states, instrument for instrument.

    Primary source ↗
View all 33 entries, back to Sep 30, 2020 Hide earlier entries

  1. Review The NAIC refreshed its adoption map to a July 7, 2026 status date. The 25 adopting jurisdictions and four independent-framework states did not change.

    Primary source ↗

  2. Adopted Hawaii adopted the NAIC model bulletin through Insurance Commissioner Memorandum No. 2025-13A.

    Primary source ↗

  3. Adopted Wisconsin's Office of the Commissioner of Insurance adopted the NAIC model bulletin in an insurance bulletin that carries a date but no number.

    Primary source ↗

  4. Adopted New Jersey adopted the NAIC model bulletin through Insurance Bulletin No. 25-03.

    Primary source ↗

  5. Adopted Delaware adopted the NAIC model bulletin in Domestic and Foreign Bulletin No. 148.

    Primary source ↗

  6. Adopted North Carolina's Department of Insurance adopted the NAIC model bulletin as Bulletin No. 24-B-19.

    Primary source ↗

  7. Adopted Massachusetts adopted the NAIC model bulletin through Bulletin No. 2024-10.

    Primary source ↗

  8. Adopted Oklahoma adopted the NAIC model bulletin as Bulletin No. 2024-11.

    Primary source ↗

  9. Adopted Iowa's Insurance Division adopted the NAIC model bulletin in Insurance Division Bulletin 24-04.

    Primary source ↗

  10. Adopted West Virginia adopted the NAIC model bulletin as Insurance Bulletin No. 24-06.

    Primary source ↗

  11. Adopted Michigan's Department of Insurance and Financial Services adopted the NAIC model bulletin through Bulletin 2024-20-INS.

    Primary source ↗

  12. Adopted Arkansas adopted the NAIC model bulletin as Bulletin 13-2024.

    Primary source ↗

  13. Adopted Virginia adopted the NAIC model bulletin through Administrative Letter 2024-01 rather than a numbered bulletin.

    Primary source ↗

  14. Own rules New York wrote its own rules rather than adopting the model bulletin: Insurance Circular Letter No. 7 sets fairness-testing and governance expectations for underwriting and pricing.

    Primary source ↗

  15. Adopted Nebraska adopted the NAIC model bulletin as Insurance Guidance Document No. IGD-H1, a guidance document rather than a bulletin.

    Primary source ↗

  16. Adopted The District of Columbia adopted the NAIC model bulletin as Bulletin 24-IB-002-05/21.

    Primary source ↗

  17. Adopted Maryland's Insurance Administration adopted the NAIC model bulletin in Bulletin No. 24-11.

    Primary source ↗

  18. Adopted Washington adopted the NAIC model bulletin as Technical Assistance Advisory 2024-02, the same day Maryland adopted its own.

    Primary source ↗

  19. Adopted Kentucky adopted the NAIC model bulletin as Bulletin No. 2024-02.

    Primary source ↗

  20. Adopted Pennsylvania adopted the NAIC model bulletin as Insurance Notice 2024-04, published in the Pennsylvania Bulletin at 54 Pa.B. 1910.

    Primary source ↗

  21. Adopted Rhode Island adopted the NAIC model bulletin as Insurance Bulletin No. 2024-03.

    Primary source ↗

  22. Adopted Illinois adopted the NAIC model bulletin through Company Bulletin 2024-08.

    Primary source ↗

  23. Adopted Vermont adopted the NAIC model bulletin as Insurance Bulletin No. 229.

    Primary source ↗

  24. Adopted Connecticut adopted the NAIC model bulletin as Bulletin No. MC-25.

    Primary source ↗

  25. Adopted Nevada adopted the NAIC model bulletin as Bulletin 24-001.

    Primary source ↗

  26. Adopted New Hampshire adopted the NAIC model bulletin as Bulletin Docket #INS 24-011-AB.

    Primary source ↗

  27. Adopted Alaska was the first jurisdiction to adopt the NAIC model bulletin, issuing Bulletin B 24-01 four weeks before the second.

    Primary source ↗

  28. Own rules Colorado adopted Regulation 10-1-1 (3 CCR 702-10), the only state framework that makes insurers run quantitative bias tests rather than just document governance.

    Primary source ↗

  29. Own rules California got there first: Bulletin 2022-5 landed 18 months before the NAIC model bulletin existed, aimed at racial bias and unfair discrimination in marketing, rating, underwriting and claims.

    Primary source ↗

  30. Own rules Texas issued Bulletin B-0036-20 on insurers' use of third-party data, the instrument the NAIC still lists as the state's framework rather than an adoption of the model bulletin.

    Primary source ↗

Status follows the NAIC's implementation map, and every instrument was checked against the issuing department's own publication. Not legal advice. How this tracker is sourced and updated →