How to Test ECDIS and AIS for Unfair Discrimination Under NY DFS Circular Letter No. 7
How to run and document the NY DFS Circular Letter No. 7 unfair-discrimination tests: which test, who owns it, what to keep.
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U.S. HOUSE · SEP 6, 2026 · Doctors Not AI Act Would Bar AI From Clinical Denials in Employer and Individual Health Plans NAIC · SEP 3, 2026 · NAIC Vendor Registry Draws Eleven Comment Letters, Then a Regulator-Only Revision Round NAIC · SEP 3, 2026 · NAIC Puts a Security Review Between Its Breach Portal and the Executive Committee NAIC · AUG 31, 2026 · NAIC Exposes the AI Risk Evaluation Supplement With Comments Due September 29 NAIC · AUG 31, 2026 · Only One Document on File for the NAIC's Prior Authorization Meeting Mentions AI
Start here
Insurance is regulated state by state, and almost nothing about AI there is written in an AI law. Start with how the machine works.
Start from the beginning →
NAIC guidance, state laws, and federal moves, plus how to build a program that meets them.
All governance coverage →
How AI is used across claims, underwriting, and pricing, plus what regulators expect.
All business-line coverage →Editor's Picks
Will AI Replace Insurance Agents? The Work Is Splitting
Will AI replace insurance agents? What current employment projections can show, which tasks are changing, and where agency AI use creates compliance exposure.
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What Trump's AI Executive Order (EO 14365) Means for State Insurance Regulation
Trump's AI executive order tells agencies to challenge state AI laws. Why McCarran-Ferguson still shields state insurance rules, and how far the federal push has got.
Inside the NAIC AI Model Bulletin
What the NAIC AI Model Bulletin is, how adoption works, what belongs in a written AIS Program, and which implementation guide to use next.
The State Tracker
Which states adopted the NAIC AI model bulletin, which wrote their own rules, and the primary source behind every row.
- Adopted
- 24 + DC
- Own rules
- 4
- None
- 22
The Vendor Directory
Which AI vendors sell to insurers, who owns each of them now, and the source behind every line.
- Insurance AI vendors
- 36
- AI governance vendors
- 11
Latest Guides
All guides →How to Identify the High-Risk AI Systems Exhibit C Asks About
Five screening lines that turn an existing AI inventory into a defensible list of the high-risk systems NAIC Exhibit C asks about, and the record behind it.
Who Owns the Evidence in Insurance AI Governance
Insurance AI governance roles as an ownership matrix: which function prepares each piece of NAIC evidence, which one signs it, and who answers for it in an exam.
What to Keep in an Insurance AI Decision Evidence Pack
Insurance AI decision documentation for reconstructing one underwriting or claims outcome, including human review, notice, appeal, and model version.
Conversational AI in Insurance and Where the Rules Reach
What conversational AI and chatbots actually do across insurance, from quotes to claims, and the point where a customer-facing bot becomes a compliance question.
AI Governance Documents to Prepare for a Market Conduct Exam
The insurance AI exam documentation to have ready for a market conduct exam: an insurer-built readiness file of eight evidence categories, and how to record a gap.
AI Model Monitoring After the Model Goes Live
A playbook for insurers on AI model monitoring, validation, drift detection, and retesting records that satisfy NAIC Model Bulletin and Exhibit C expectations.
From the Glossary
All 87 terms →Plain-language definitions of the NAIC and insurance AI governance terms we use across the site.
- Accelerated Underwriting
- A life insurance underwriting process that uses external data and predictive models to classify applicants without medical exams or fluid tests.
- Alternative Data
- Data not traditionally used in underwriting, such as credit history, driving behavior, or digital signals. Often regulated as ECDIS when applied to consumers.
- Consumer Recourse
- The rights consumers have to appeal, correct, or contest an AI-influenced insurance decision, a central feature of Colorado SB 26-189 and similar state laws.
- Exhibit B
- The NAIC AI Evaluation Tool's governance exhibit, answered as a narrative or a checklist, asking where an insurer's framework already covers each listed item.
- Governance Committee
- A cross-functional group that oversees AI risk, approves deployments, and reviews testing. Must meet regularly and have authority to pause AI systems.
- Medical Necessity
- Whether a service is clinically warranted enough to be covered. In California and in Medicare Advantage, a licensed clinician has to make that call, not a tool.
- NAIC Big Data and AI (H) Working Group
- The NAIC group that handles insurance AI. Its page is where the evaluation tool drafts, the bulletin adoption map, and the meeting materials are posted.
- Proxy Test
- The assessment NYDFS expects on external consumer data: does it correlate with protected-class status, and if so, does a business necessity require it?
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