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Pennsylvania Enacts New Digital Forgery Law

On July 7, 2025, Pennsylvania Governor Josh Shapiro enacted a new Digital Forgery Law by signing SB 649 into law, which will take effect in 60 days. SB 649 creates “new criminal penalties for anyone who uses artificial...more

NAIC Responds to Proposed 10-Year Moratorium on State Regulation of AI in One Big Beautiful Bill Act

There is a proposed 10-year moratorium on the enforcement of state laws that regulate artificial intelligence (AI) contained in Section 43201(c) of H.R.1 – One Big Beautiful Bill Act. ...more

Wisconsin Becomes the 24th State to Adopt the NAIC Model Bulletin on the Use of AIS in Insurance

On March 18, Wisconsin Insurance Commissioner Nathan Houdek issued Wisconsin’s new bulletin on the use of artificial intelligence systems (AIS) in insurance, becoming the 24th state to adopt the NAIC Model Bulletin on the Use...more

NAIC Establishes the Risk-Based Capital Model Governance (EX) Task Force in 2025

The 2025 National Association of Insurance Commissioners (NAIC) President and North Dakota Insurance Commissioner Jon Godfread has stated that...more

New Jersey Adopts Bulletin on AI Use in Insurance

On February 11, New Jersey Banking and Insurance Commissioner Zimmerman issued Bulletin 25-03 regarding the use of artificial intelligence systems (AIS) in insurance, applicable to all insurers authorized or admitted in New...more

Delaware Insurance Commissioner Navarro Issues Bulletin No. 148 Re: Use of Artificial Intelligence Systems in Insurance

On February 5, Delaware joined 21 jurisdictions who adopted guidance similar to the NAIC Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers in 2024, and four additional jurisdictions have otherwise...more

Artificial Intelligence State Insurance Regulation: A Year in Review

Much of the activity surrounding the state insurance regulation of artificial intelligence (“AI”) in the insurance industry this year was prompted by the NAIC Model Bulletin: Use of Artificial Intelligence Systems by Insurers...more

Oklahoma Issued Bulletin 2024-11: Use of Artificial Intelligence ‎Systems in Insurance

On November 14, 2024, Oklahoma issued Bulletin 2024-11: Use of Artificial Intelligence Systems in Insurance....more

Iowa Insurance Division Releases Proposed AI Bulletin for Comment

On October 10, 2024, the Iowa Insurance Division released for comment a proposed AI Bulletin based upon the NAIC AI Model Bulletin. Comments are due before October 31, 2024....more

NY DFS Issues an Industry Letter Regarding AI Cyber Guidance

On October 16, 2024, the NY DFS issued an Industry Letter explaining “how Covered Entities should use the framework set forth in Part 500 to assess and address the cybersecurity risks arising from AI.”...more

West Virginia Issued Bulletin No. 24-06 RE: Artificial ‎Intelligence

On August 9, 2024, the West Virginia Office of the Insurance Commissioner issued Bulletin 24-06 on Artificial Intelligence Systems (“Bulletin”). The Bulletin is applicable to “all insurers authorized to do business in West...more

Michigan Issued Bulletin 2024-20-INS RE: Use of AIS in ‎Insurers

On August 7, 2024, Michigan issued Bulletin 2024-20-INS on the Use of Artificial Intelligence Systems By Insurers. The Bulletin is applicable to all Insurers, Nonprofit Health Services Plans, HMOs, and Dental Plan...more

Arkansas Issued Bulletin 13-2024 RE: Use of AIS in Insurance

On July 31, 2024, Arkansas issued Bulletin 13-2024 on the Use of Artificial Intelligence Systems in Insurance. The Bulletin is applicable to all companies licensed to do business in Arkansas and is based upon the NAIC Model...more

Virginia Issued Administrative Letter 2024-01 RE: Use of AIS‎

On Monday, July 22, 2024, the Virginia Bureau of Insurance (“Bureau”) issued Administrative Letter 2024-01 on the Use of Artificial Intelligence Systems which is applicable to all companies licensed to conduct the business of...more

New York DFS Issues Circular Letter No. 7 RE: Use of AIS and ECDIS in Insurance Underwriting and Pricing

On Thursday, July 11, 2024, the New York Department of Financial Services (“NYDFS”) issued Circular No. 7 Re: Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting...more

Nebraska Adopts AI Guidance

On June 11, 2024, the Nebraska Insurance Department issued Guidance IGD-H1 on the Use of AI By Insurers. This brings the total to 13 jurisdictions that have adopted the NAIC Model Bulletin on the Use of AI Systems in...more

PHL Variable Insurance Company in ‎Rehabilitation At A Glance

On Friday, May 17, 2024, Connecticut Insurance Commissioner Mais filed a Petition for Rehabilitation and Appointment of the Commissioner as Rehabilitator of PHL Variable Insurance Company ("PHL"), a Connecticut domestic stock...more

DC Adopts Bulletin 24-IB-002-05/21 on the Use of Artificial Intelligence Systems in Insurance

On May 21, 2024, the DC Insurance Commissioner, Karima M. Woods, issued Bulletin 24-IB-002-05/21 on the Use of Artificial Intelligence Systems in Insurance to all Insurers licensed to do business in the District of Columbia....more

Washington Issues Technical Assistance Advisory 2024-02 Regarding the Use of AI in ‎Insurance

On April 22, 2024, the Washington Office of the Insurance Commissioner issued Technical Assistance Advisory 2024-02 regarding “The Use of Artificial Intelligence Systems in Insurance” (the “Advisory”). The Advisory applies to...more

Kentucky Issues Bulletin 2024-02 on the Use of AI in Insurance

On April 16, 2024, the Kentucky Department of Insurance issued Bulletin 2024-02 to all insurers licensed to do business in Kentucky regarding the Use of Artificial Intelligence Systems in the Business of Insurance effective...more

Maryland Issues Bulletin No. 24-11 on the Use of AI in Insurance

Commissioner Kathleen Birrane, Maryland Insurance Administration, on April 22, 2024 issued Bulletin No. 24-11, The Use of Artificial Intelligence Systems in Insurance (the “Bulletin”). The Bulletin applies to “all Insurers,...more

Illinois Appoints New Insurance Director

Effective April 15, 2024, Illinois will have a new Acting Insurance Director, Illinois State Senator Ann Gillespie....more

Pennsylvania Adopts NAIC Model Bulletin on the Use of Artificial Intelligence by Insurers

On Saturday, April 6, 2024, Pennsylvania adopted 54 Pa.B. 1910 based upon the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers; Notice 2024-04....more

Colorado Division of Insurance Holds Second Health Insurance Stakeholder Meeting for ‎Implementing AI Requirements

On Tuesday, April 2, 2024, the Colorado Division of Insurance (“Division”) held its second Unfair Discrimination in Insurance Practices – Health Insurance Stakeholder meeting where the Division discussed efforts to develop...more

NAIC Model Bulletin on the Use of AI Systems by Insurers Adopted in Eight States

Nevada has adopted the NAIC Model Bulletin on the Use of AI Systems by Insurers along with seven other states, including Alaska, Connecticut, Illinois, New Hampshire, Nevada, Rhode Island and Vermont....more

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