Model Law
A template statute the NAIC drafts for states to adopt as binding law. Unlike a Model Bulletin, it has the force of law once a state legislature adopts it.
A Model Law is a draft statute developed by the NAIC for state legislatures to adopt as state law. Once a state passes it, the Model Law has the full force of law in that state, including penalties for non-compliance. Common insurance Model Laws cover topics such as unfair trade practices, insurance holding companies, and market conduct.
A Model Bulletin is different. It is guidance issued by the NAIC to state insurance regulators, explaining how to apply existing laws to new issues. The NAIC Model Bulletin on AI does not create a new statute; it tells examiners how to apply unfair-trade-practices and unfair-discrimination laws to AI systems. A state can adopt a Model Bulletin through its insurance department without legislative action.
The distinction matters for carriers. A Model Law, once adopted, is a statute that must be followed. A Model Bulletin, while influential, is guidance that may be adopted, modified, or simply used as an examination framework by state regulators. See our guides to the NAIC and the NAIC Model Bulletin.