Category: Insurance | Reading time: 4 min
The Adoption Curve
As of early 2026, at least 24 states and the District of Columbia have adopted the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, or substantially similar guidance. The NAIC stated in December 2025 that over half of all states had adopted the bulletin or similar measures.
Adopting jurisdictions include Alaska, Arkansas, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Iowa, Kentucky, Maryland, Massachusetts, Michigan, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, Oklahoma, Pennsylvania, Rhode Island, Vermont, Virginia, Washington, West Virginia and Wisconsin.
That pace is unusual for an NAIC model product.
Why It Spread So Fast
The bulletin was designed to fit within existing state regulatory authority. It does not require new legislation, only a bulletin from the state insurance commissioner.
That design choice removed the slowest step in state regulatory adoption. It also means each state issued its own instrument on its own date, with its own wording.
Adoption dates run from Vermont Bulletin No. 229 in March 2024 through Hawaii Insurance Commissioner Memorandum No. 2025-13A in December 2025, with many jurisdictions in between.
The Multi State Problem
For a carrier or agency licensed in several states, the practical consequence is that there is no single programme that satisfies the full regulatory footprint.
Each state adoption of the model bulletin, the NAIC AI Systems Evaluation Tool, and any independent state AI legislation has to be mapped against the specific appointments or licences held.
Illinois has both adopted the model bulletin and passed independent legislation. New York existing NYDFS Part 500 framework creates parallel obligations for entities licensed by the Department of Financial Services. Those are different instruments with different scopes reaching the same operations.
The floor is rising in every jurisdiction, and it is rising unevenly.
What The Bulletin Expects
The model bulletin expects insurers to maintain a written AI governance programme covering the full lifecycle of AI systems used in insurance operations, with attention to the risk of adverse consumer outcomes.
Regulators have begun piloting examination tools against it. Third party vendor documentation is an area where more specific requirements have been drafted.
The Federal Overlay
A federal executive order challenging state authority over AI regulation created a preemption question that remains unresolved.
The NAIC response in December 2025 was direct, noting that state insurance regulators have overseen the market for over 150 years.
Carriers are left preparing for a state patchwork while a federal challenge to that patchwork proceeds. Neither outcome removes the underlying obligation to be able to explain how an AI system reached a decision affecting a policyholder.
The Common Denominator
Across 24 jurisdictions with different bulletins and different dates, the evidentiary expectation is consistent. A regulator asks what the system did, on whose authority, and whether a human was positioned to intervene.
That answer is the same in every state. What differs is which instrument compels it.