State Insurance Departments Just Quietly Regulated AI — The 24 Jurisdictions That Did It (2026)
While journalists watched California, Colorado, and Congress, state insurance commissioners did something neither legislatures nor the White House managed: put binding AI-governance expectations on a regulated industry. The vehicle is one NAIC model document — adopted by 24 jurisdictions.
While journalists were watching California, Colorado, and Congress, state insurance commissioners were busy doing something neither legislatures nor the White House have managed: putting actual, binding AI-governance expectations on a regulated industry. The vehicle is the NAIC's Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, adopted by the NAIC on December 4, 2023. As of June 2026, two dozen U.S. jurisdictions (states plus D.C.) have adopted it — usually with minimal customization. Here is the list, with bulletin numbers and adoption dates. The full sourced national entry is on the live map.
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1. Alaska — Bulletin B 24-01
Alaska (state) · Adopted February 1, 2024Alaska adopted the NAIC AI Model Bulletin as Bulletin B 24-01, applying its AI Systems Program governance expectations to insurers writing in the state.
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2. Arkansas — Bulletin 13-2024
Arkansas (state) · Adopted July 31, 2024Arkansas adopted the NAIC AI Model Bulletin as Bulletin 13-2024.
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3. Connecticut — Bulletin MC-25
Connecticut (state) · Adopted February 26, 2024Connecticut adopted the NAIC AI Model Bulletin as Bulletin No. MC-25.
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4. Delaware — Bulletin No. 148
Delaware (state) · Adopted February 5, 2025Delaware adopted the NAIC AI Model Bulletin as Bulletin No. 148.
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5. District of Columbia — DISB AI Bulletin
District of Columbia · Adopted May 21, 2024D.C.'s Department of Insurance, Securities and Banking adopted the NAIC AI Model Bulletin in May 2024.
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6. Illinois — Company Bulletin CB 2024-08
Illinois (state) · Adopted March 13, 2024Illinois adopted the NAIC AI Model Bulletin as Company Bulletin CB 2024-08.
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7. Iowa — AI Model Bulletin
Iowa (state) · Adopted November 7, 2024Iowa's Insurance Division adopted the NAIC AI Model Bulletin in November 2024.
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8. Kentucky — AI Model Bulletin
Kentucky (state) · Adopted April 16, 2024Kentucky's Department of Insurance adopted the NAIC AI Model Bulletin in April 2024.
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9. Maryland — Bulletin 24-11
Maryland (state) · Adopted April 22, 2024Maryland adopted the NAIC AI Model Bulletin as Bulletin 24-11.
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10. Massachusetts — Bulletin 2024-10
Massachusetts (state) · Adopted December 9, 2024Massachusetts adopted the NAIC AI Model Bulletin as Bulletin 2024-10.
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11. Michigan — Bulletin 2024-20-INS
Michigan (state) · Adopted August 7, 2024Michigan adopted the NAIC AI Model Bulletin as Bulletin 2024-20-INS.
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12. Nebraska — AI Model Bulletin
Nebraska (state) · Adopted February 23, 2024Nebraska's Department of Insurance adopted the NAIC AI Model Bulletin in February 2024.
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13. Nevada — AI Model Bulletin
Nevada (state) · Adopted February 23, 2024Nevada's Division of Insurance adopted the NAIC AI Model Bulletin in February 2024.
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14. New Hampshire — AI Model Bulletin
New Hampshire (state) · Adopted February 20, 2024New Hampshire's Insurance Department adopted the NAIC AI Model Bulletin in February 2024.
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15. New Jersey — Bulletin No. 25-03
New Jersey (state) · Adopted February 11, 2025New Jersey adopted the NAIC AI Model Bulletin as Bulletin No. 25-03 (BLT25_03).
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16. North Carolina — Bulletin 24-B-19
North Carolina (state) · Adopted December 18, 2024North Carolina adopted the NAIC AI Model Bulletin as Bulletin 24-B-19.
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17. Oklahoma — Bulletin No. 2024-11
Oklahoma (state) · Adopted November 14, 2024Oklahoma adopted the NAIC AI Model Bulletin as Bulletin No. 2024-11 — the regulator-driven workaround after HB 3577 died in the legislature.
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18. Pennsylvania — Insurance Department Notice
Pennsylvania (state) · Adopted April 6, 2024Pennsylvania's Insurance Department adopted the NAIC AI Model Bulletin via department notice in April 2024.
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19. Rhode Island — Insurance Bulletin
Rhode Island (state) · Adopted March 15, 2025Rhode Island adopted the NAIC AI Model Bulletin in March 2025.
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20. Vermont — Bulletin No. 229
Vermont (state) · Adopted March 12, 2024Vermont adopted the NAIC AI Model Bulletin as Bulletin No. 229.
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21. Virginia — Administrative Letter AL-2024-01
Virginia (state) · Adopted July 22, 2024Virginia's Bureau of Insurance adopted the NAIC AI Model Bulletin as Administrative Letter AL-2024-01.
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22. Washington — Technical Assistance Advisory 2024-02
Washington (state) · Adopted April 22, 2024Washington's Office of the Insurance Commissioner adopted the NAIC AI Model Bulletin as Technical Assistance Advisory 2024-02.
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23. West Virginia — Informational Bulletin IB 24-06
West Virginia (state) · Adopted August 9, 2024West Virginia adopted the NAIC AI Model Bulletin as Informational Bulletin IB 24-06.
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24. Wisconsin — Bulletin (March 18, 2025)
Wisconsin (state) · Adopted March 18, 2025Wisconsin's Office of the Commissioner of Insurance adopted the NAIC AI Model Bulletin in March 2025.
What insurers actually have to do: in adopting states, insurers are expected to maintain a written AI Systems Program covering every AI system used in claims, underwriting, rating, fraud detection, or marketing; designate accountable senior leadership; conduct pre-deployment risk assessments for discrimination, accuracy, and explainability; document third-party AI vendors; and cooperate with regulator inquiries. Why it matters: insurance is the only major U.S. consumer industry where AI is already subject to enforceable governance expectations across roughly half the country — pulled off quietly in under 24 months by adopting a single model document. What to watch: the remaining holdouts (Florida, Georgia, New York, Ohio, Tennessee, Texas — though NY DFS has its own Circular Letter No. 7 of 2024); the first market-conduct exam findings grounded in the bulletin; and at least three states weighing statutory escalation with private rights of action. See the full sourced entry on the live map.