NAIC Model Bulletin Adoption Now Spans Most States
As of the NAIC’s April 2026 adoption map, 24 states and the District of Columbia have formally adopted the AI Model Bulletin originally adopted December 4, 2023. Four more (California, Colorado, New York, and Texas) regulate insurance AI through their own guidance rather than the model. The map is the authoritative status source, but the differences between each state’s version are where the practical work lies.
For compliance officers, the headline is less useful than the footnotes. Adoption is not a single on/off switch. Some states adopt the model verbatim. Others attach interpretive guidance, state-specific timing, or additional notice requirements. A carrier that treats the bulletin as a uniform national standard will miss the seams where its own state has added or softened language. The first task is to map which states your company writes in, which version of the bulletin each has adopted, and whether the state has issued any companion guidance or circular letter that changes how examiners will read it.
The second task is to stop reading adoption as exemption. Even in states that have not adopted the model, AI-assisted insurance decisions still sit under existing unfair-trade-practices, unfair-discrimination, and unfair-claims-settlement statutes. The bulletin does not create new authority in states that adopt it; it tells examiners where to look. In states that have not adopted it, the underlying authority is still there, but the carrier has fewer clues about what the examiner expects to see. That can be harder, not easier.
The four independent states matter because they are usually the largest markets and the most active examiners. California, Colorado, New York, and Texas each have their own frameworks, and a carrier operating in all four is running four parallel compliance programs. Colorado’s SB21-169 and SB26-189 impose notice and recourse obligations beyond the model. New York’s Circular Letter 7 sets specific expectations for underwriting and pricing AI. California Bulletin 2022-5 focuses on unfair discrimination in underwriting. Texas has directed its Department of Insurance to review AI use in rating and claims. These are not minor variations. They are separate regulatory tracks that happen to share a topic.
Carriers should now do three things. First, pull the NAIC map and compare it against your state footprint. Second, for each state where you write, identify the exact mechanism: model bulletin adoption, state-specific guidance, or independent legislation. Third, pressure-test your AI Systems Program against the most demanding state in your footprint, not the average. A program that satisfies the median adopter will fail in the most demanding state. That is the standard that matters.
The same logic applies to distribution and M&A. A carrier acquiring a smaller writer in a new state inherits that state’s bulletin version and any companion rules. A managing general agency or third-party administrator using your paper may create AI exposure in a state your compliance team has not mapped. The adoption count is a snapshot; the state footprint is a moving target. Keeping the two aligned should be a standing item on the AI governance committee agenda, not an annual project.
For the rule-by-rule breakdown of what the bulletin asks you to build, see our guide to the NAIC AI Model Bulletin.