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The CCPA’s automated decisionmaking tool rules: New consumer rights and compliance challenges

On July 24, 2025, the California Privacy Protection Agency (CPPA) unanimously adopted a comprehensive rulemaking package under the California Consumer Privacy Act (CCPA) that primarily addresses automated decisionmaking...more

NAIC proposes evaluation tool for AI systems used by insurers

On July 7th, the NAIC’s Big Data and AI Working Group (Working Group) exposed a draft of an AI Systems Evaluation Tool (Evaluation Tool). The stated purpose is to provide regulators with a tool that enables them to identify...more

AI regulation Texas-style: The Texas Responsible Artificial Intelligence Governance Act

The Texas Responsible Artificial Intelligence Governance Act (TRAIGA), which was signed into law by Governor Greg Abbott on June 22, 2025, and is effective January 1, 2026, establishes a framework for regulating the...more

CFPB withdraws dozens of guidance documents in sweeping regulatory shift

Consistent with President Trump’s de-regulatory agenda, the Consumer Financial Protection Bureau (CFPB or Bureau) is withdrawing over five dozen of its guidance documents, including interpretive rules, advisory opinions, and...more

Recent Executive Order on disparate impact: what it means for insurer’s use of AI

On April 23, 2025, President Donald Trump issued an Executive Order titled “Restoring Equality of Opportunity and Meritocracy” (order). The order declares disparate impact theory to be “wholly inconsistent with the...more

DOJ cracks down on data transfers

Proposed rule would create new prohibitions on transactions of sensitive personal data and government-related data - The Department of Justice (DOJ) has proposed a new rule aimed at preventing access of China and other...more

AI at the gate: NYDFS issues guidance on addressing new AI-driven cybersecurity risks under existing cybersecurity requirements

On October 16, 2024, the New York State Department of Financial Services (DFS) issued an industry letter providing guidance on how DFS-regulated entities (covered entities) should be evaluating and responding to artificial...more

Beyond the binary: How NIST is shaping the policies and practices of AI innovation and risk management

On September 24th and 25th, the National Institute of Standards and Technology (NIST) convened a symposium to generate new insights about the next steps needed to unleash AI innovations that will enable trust in this...more

Connecticut Insurance Department adopts NAIC model bulletin on AI

On February 26, 2024, the Connecticut Insurance Department (the CID) adopted Bulletin No. MC-25 on the “Use of Artificial Intelligence Systems in Insurance” (Connecticut Bulletin). This Connecticut Bulletin is similar to the...more

Global AI Regulatory Update - February 2024

Welcome to our quarterly Global AI Regulatory Update, summarizing key developments from around the world. On November 27, 2023, AI Security Guidelines were published. The guidelines were led by UK National Cyber Security...more

New York Department of Financial Services proposes a circular letter on the use of artificial intelligence to underwrite insurance

On January 17, 2024, the New York State Department of Financial Services (NY DFS) released for public comment a proposed circular letter (Proposed Letter) to regulate the use of artificial intelligence systems (AIS) and...more

Testing for AI bias: Colorado Division of Insurance proposes first-of-its kind regulation requiring life insurers to test their...

On September 28, 2023, the Colorado Division of Insurance (CDI) released the first-of-its kind draft proposed regulation (Testing Regulation) for testing the outcomes of certain life insurance underwriting practices for...more

New York Raises the Bar Again: Revised Cybersecurity Requirements for Financial Services Companies Finalized

On November 1, 2023, the New York Department of Financial Services (NY DFS) published its highly anticipated final amendments to its influential cybersecurity requirements for financial services companies (Part 500)....more

Updata: Your quarterly privacy & cybersecurity update - July - September 2023

Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s dedicated Privacy and Cybersecurity team. Updata provides you with a compilation of privacy and cybersecurity regulatory and...more

Colorado Division of Insurance adopts final rule on use of big data and predictive models

The Colorado Division of Insurance (CDI) adopted a new regulation on September 21, 2023 (Final Regulation) establishing requirements governing the use of external consumer data and information sources (ECDIS), as well as...more

NAIC releases highly-anticipated draft model bulletin on artificial intelligence systems used by insurers

On July 17, 2023, the Innovation, Cybersecurity and Technology (H) Committee of the National Association of Insurance Commissioners (NAIC) released for comment a highly anticipated model bulletin (Model Bulletin) on...more

Colorado Division of Insurance proposes significant revisions to its draft algorithm and predictive model governance regulation...

On May 26, 2023, the Colorado Division of Insurance (CDI) exposed, for public review and comment, a significantly revised draft of its proposed regulation (the Revised Draft Reg.) addressing the governance and risk management...more

Updata: Your quarterly privacy & cybersecurity update - January to March 2023

Welcome to the latest edition of Updata! Updata is an international report produced by Eversheds Sutherland’s dedicated Privacy and Cybersecurity team – it provides you with a compilation of key privacy and cybersecurity...more

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