News & Analysis as of

Artificial Intelligence NAIC Insurance Regulations

Zelle  LLP

AI Update: Insurance Commissioners Challenge One Big Beautiful Bill Act’s Definition of Artificial Intelligence

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One Big Beautiful Bill Act (“OBBA”) which would impose a 10-year freeze on new state-level artificial intelligence regulations and suspend enforcement of existing ones is being challenged by several state insurance...more

Troutman Pepper Locke

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

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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

Carlton Fields

States Build the Next Mile of Artificial Intelligence Regulation

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Since the start of 2025, the following states have added to the roadwork on artificial intelligence regulation in insurance by implementing the NAIC’s model bulletin on the use of AI systems by insurers...more

Carlton Fields

NAIC Big Data Working Group Continues Building a Regulatory Structure

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During the NAIC Spring National Meeting, the Big Data and Artificial Intelligence (H) Working Group reviewed its blueprint to build an overarching regulatory edifice to oversee insurers’ use of artificial intelligence...more

Mitchell, Williams, Selig, Gates & Woodyard,...

National Association of Insurance Commissioners (NAIC) Spring 2025 Meeting Summary

The Mitchell Williams Insurance Regulatory team of attorneys recently attended the National Association of Insurance Commissioners (NAIC) Spring 2025 National Meeting which was held in Indianapolis, Indiana. We have prepared...more

Maynard Nexsen

NAIC Spring Meeting Update Part One

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The Maynard Nexsen Insurance Regulatory team of attorneys attended the National Association of Insurance Commissioners (NAIC) Spring National Meeting held on March 23-26 in Indianapolis, Indiana. As expected, regulators,...more

Quarles & Brady LLP

Nearly Half of States Have Now Adopted NAIC Model Bulletin on Insurers’ Use of AI

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As of March 2025, 24 states have adopted the National Association of Insurance Commissioners (NAIC) Model Bulletin on the Use of Artificial Intelligence (AI) Systems by insurers with little to no material changes. As we...more

Troutman Pepper Locke

New Jersey Adopts Bulletin on AI Use in Insurance

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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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Carlton Fields

Will Insurers Be Required to Don a Deerstalker? The Case of Third-Party Vendors in Insurance

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Regulators are growing concerned about the delegation of various insurance company functions, prompting a closer examination of third-party vendors. Several groups within the National Association of Insurance Commissioners...more

Carlton Fields

A Bird's-Eye View of the Current Standings of AI Guidance and Requirements by States

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Since the 2023 adoption by the National Association of Insurance Commissioners of its model bulletin on the use of AI systems by insurers, states have been adopting the model bulletin or draft requirements of their own. Below...more

Paul Hastings LLP

An Eye on Insurance: Recent Developments in Insurance Regulation - UPDATED September 2024

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2024 has seen a significant amount of activity by state insurance regulators and the National Association of Insurance Commissioners (the “NAIC”) including the adoption of major revisions to the regimes governing investments...more

Quarles & Brady LLP

States Adopt NAIC Model Bulletin on Insurers’ Use of AI

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State regulators are taking action on the use of artificial intelligence in insurance. To date, nearly a dozen states have adopted some form of the National Association of Insurance Commissioners (NAIC) Model Bulletin on the...more

Carlton Fields

NAIC Groups Carve Up the Mountain at the Winter Meeting

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After strapping on their skis and riding up the lifts, the NAIC groups reported to their events. The results of the events of note for life insurers are as follows...more

Eversheds Sutherland (US) LLP

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

BakerHostetler

NAIC Adopts Model Bulletin on Artificial Intelligence

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On December 4, the National Association of Insurance Commissioners unanimously adopted a model bulletin on the use of artificial intelligence in insurance. The model bulletin is intended for use by state insurance regulators...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Carlton Fields

NAIC Innovation, Cybersecurity, and Technology (H) Committee Gets in on the Action

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On July 17, the Innovation, Cybersecurity, and Technology (H) Committee of the National Association of Insurance Commissioners released its exposure draft of the NAIC’s model bulletin on insurers’ use of algorithms,...more

Carlton Fields

Regulators Looking to Various Kitchen Tools to Regulate Insurers’ Use of Artificial Intelligence and Machine Learning

Carlton Fields on

Various chefs within the National Association of Insurance Commissioners and some individual states’ chefs continue to address insurers’ use of artificial intelligence (AI), machine learning (ML), the use and protection of...more

Carlton Fields

Topsy-Turvy World of Accelerated Underwriting and Artificial Intelligence

Carlton Fields on

As accelerated underwriting (AU) and artificial intelligence (AI) begin to turn life underwriting upside down, several NAIC working groups are seeking to bring order to the disruption: the Big Data (EX) Working Group (“Big...more

Carlton Fields

Innovation and Technology at the NAIC 2019 Fall Meeting

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Several NAIC groups continued addressing issues related to innovation in the life insurance industry as follows...more

Morgan Lewis

New Laws And Regulations: Insights For 2020

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A constantly evolving framework of laws governing how multinational businesses can contact customers to how nonprofits report business income to how overtime is calculated and paid will influence how companies do business...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update - December 2019

In this month's edition of our Privacy & Cybersecurity Update, we take a look at guidance on artificial intelligence released by the U.K. Information Commissioner's Office and the Turing Institute, as well as guidance...more

Carlton Fields

Innovation Whack-a-Mole

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Like a game of whack-a-mole, new or existing NAIC groups are being tasked to consider the various regulatory issues that are popping up from insurance innovation....more

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