States Decode Their Expectations on Insurers’ Use of AI

States continue to decode their expectations regarding insurers’ use of artificial intelligence (AI) systems. Since our last report, the following states have issued bulletins based on the National Association of Insurance Commissioners’ model bulletin on the use of AI systems.

1. Iowa (November 7, 2024), whose bulletin notes that the Iowa Insurance Division also anticipates providing supplementary guidance on the governance of third-party AI systems.
2. Oklahoma (November 14, 2024)
3. Massachusetts (December 9, 2024), whose bulletin notes that the Massachusetts Division of Insurance also intends to revisit the guidance provided in the bulletin on a periodic basis and make updates as warranted. It would consider any relevant recommendations made by the AI Strategic Task Force created pursuant to the Massachusetts governor’s executive order No. 629. One objective of the task force is to recommend new policies, guidelines, or frameworks that promote responsible AI development and use, including issues related to bias, equity, privacy, security, and potential misuse of AI-generated content.
4. North Carolina (December 18, 2024)

The above-mentioned bulletins followed action by:

• The 17 jurisdictions that previously adopted the NAIC model bulletin (namely, Alaska, Arkansas, Connecticut, Illinois, Kentucky, Maryland, Michigan, Nebraska, Nevada, New Hampshire, Pennsylvania, Rhode Island, Vermont, Virginia, Washington, Washington, D.C., and West Virginia).
• California, Colorado, and New York, which previously decrypted their separate AI requirements for insurers. (The NAIC also notes Texas as having relevant guidance, though it is not specific to AI systems.)

 Also, on December 6, the Colorado Division of Insurance gave a decoder ring to private passenger automobile insurers and health benefit plans on its expectations on governance requirements by releasing for comment proposed amendments to Regulation 10-1-1. The proposed amendments would update requirements for life insurers and expand their applicability to private passenger automobile insurers and health benefit plan insurers.

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