What NAIC Model Bulletin on the Use of Artificial Intelligence by Insurance Companies (Adopted December 2023; Aligned with NAIC Principles of Artificial Intelligence Adopted at the 2020 Summer National Meeting; Developed by the Big Data and Artificial Intelligence (H) Working Group) requires
The NAIC Model Bulletin on the Use of Artificial Intelligence by Insurance Companies is the National Association of Insurance Commissioners' authoritative guidance for state insurance regulators and insurers on the responsible use of AI in insurance. The Bulletin was adopted in December 2023 by the NAIC and was developed by the Big Data and Artificial Intelligence (H) Working Group, which was established in 2019 to study the development of artificial intelligence, its use in the insurance sector, and its impact on consumer protection and privacy, marketplace dynamics, and the state-based insurance regulatory framework. The Bulletin operationalises the NAIC Principles of Artificial Intelligence that were adopted by the full NAIC membership at the 2020 Summer National Meeting. Per the NAIC's official summary, 'the bulletin establishes guidelines and expectations to ensure responsible use of AI by insurance companies that align with the NAIC Principles of Artificial Intelligence. It reminds insurers that decisions or actions made or supported by AI must comply with all applicable insurance laws and regulations, sets forth expectations as to how insurers will govern the use of AI, and advises insurers of the type of information the Department may request during an investigation or examination.' Although the Model Bulletin is not itself binding (NAIC model documents become operative only when adopted by individual state insurance departments), it is the de facto national standard and has been adopted or is in the process of adoption by many state insurance departments - the NAIC tracks adoption status on the AI Model Bulletin State Adoption Map. The Bulletin sits within a broader NAIC AI workstream that includes the AI Systems Evaluation Tool - being piloted by 12 participating states as of March 2026 to support regulators in market conduct, financial analysis and financial examination contexts - anticipated for adoption at the 2026 Fall National Meeting.
Pillar: Insurance & Risk · Authority: National Association of Insurance Commissioners (NAIC) - adopted by full NAIC membership December 2023; developed by the Big Data and Artificial Intelligence (H) Working Group; binding force depends on adoption by individual state insurance departments; tracked on the AI Model Bulletin State Adoption Map maintained by NAIC · Version: 1.0.0 · Last updated:
Primary source: https://content.naic.org/insurance-topics/artificial-intelligence
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- NAIC Model Bulletin on the Use of Artificial Intelligence by Insurance Companies - adopted by NAIC membership in December 2023
- NAIC summary of the Model Bulletin: 'The bulletin establishes guidelines and expectations to ensure responsible use of AI by insurance companies that align with the NAIC Principles of Artificial Intelligence. It reminds insurers that decisions or actions made or supported by AI must comply with all applicable insurance laws and regulations, sets forth expectations as to how insurers will govern the use of AI, and advises insurers of the type of information the Department may request during an investigation or examination.'
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