States Build the Next Mile of Artificial Intelligence Regulation

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:

Meanwhile, Colorado continues to pave its own regulatory path under Senate Bill 21-169, which directs the state to adopt rules on how companies should test and demonstrate that their use of external consumer data and sources, as well as algorithms or predictive models relying on such data, does not result in unfair discrimination.

Colorado continues construction on a draft proposed amendment to Regulation 10-1-1, which would expand the existing governance and risk management framework requirements to include private passenger automobile insurers and health benefit plan insurers. On April 22, 2025, Colorado issued notice for a June 2, 2025, virtual permanent rulemaking hearing on the proposed amendment to receive oral comments. Written comments may be submitted up to three business days after the hearing.

Colorado also laid out its plans for an upcoming data call for private passenger auto insurance during an April 18, 2025, virtual meeting.

This article was co-authored by Carlton Fields law clerk Jake Heiges.

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