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In effect Limited protection

New Hampshire ID Docket INS 24-011-AB — Use of AI Systems by Insurers (NAIC Model Bulletin adoption)

NH · New Hampshire ID Docket INS 24-011-AB (2024-02-20)

The NH Department of Insurance adopted the NAIC Model Bulletin on Use of Artificial Intelligence Systems by Insurers. Insurers licensed in NH must maintain a written AI program with governance, risk-management, testing, third-party-AI oversight, and documentation controls. The bulletin operationalizes existing unfair-trade-practice and unfair-discrimination law as applied to insurers' AI use cases — underwriting, pricing, claims, fraud detection, and marketing.

Technical detail

Adoption of the NAIC Model Bulletin on Use of AI Systems by Insurers. Establishes regulator expectations for insurer AI Systems Programs covering governance/accountability, risk identification/mitigation, model validation/testing for bias and accuracy, third-party AI vendor due diligence, ongoing monitoring, and documentation/recordkeeping sufficient to support regulator examination. Existing statutory authority: state unfair trade practices act, unfair discrimination provisions, market-conduct examination authority.

Who is protected: Consumers, applicants, claimants, and policyholders in NH whose insurance decisions involve insurer AI systems

Who must comply: All insurers licensed to write business in NH (including health, life, P&C, and reinsurance lines)

Key facts

JurisdictionNH
LevelState
StatusIn effect
Protection strengthLimited protection
Effective date2024-02-20
Enacted2024-02-20
CitationNew Hampshire ID Docket INS 24-011-AB (2024-02-20)
Enforced byNH Department / Division of Insurance
Private right of actionNo — agency enforcement only
PenaltiesStandard market-conduct examination findings, corrective action plans, fines under state unfair-trade-practices act
Topicsinsurance AI · automated decision-making · consumer protection
Last verified2026-06-16
Official sourceNAIC AI Model Bulletin Implementation Map (Apr. 1, 2026) ↗

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