Artificial intelligence now touches underwriting, pricing, marketing, and claims. State regulators have spent 2026 moving from principles to enforcement tools, and the direction is worth understanding even if you never build a model yourself.
The bulletin most states are using
In December 2023 the National Association of Insurance Commissioners adopted a model bulletin on insurers' use of AI systems. It is guidance, so it only takes effect in a state when that state's insurance department issues it. As of the NAIC's spring 2026 meeting, 24 states and the District of Columbia had done so.
The bulletin's central idea is accountability. An insurer is responsible for the decisions its AI systems make or support, including systems it bought from someone else. "The vendor built it" is not a defense.
What changed in 2026
Two developments stand out.
- Regulators are testing an examination tool. A multistate pilot of the NAIC's AI Systems Evaluation Tool began early in the year. It gives examiners a standard set of questions about how an insurer governs and tests its AI.
- Attention is shifting to vendors. At the March 2026 meeting, the NAIC working group on third-party data and models advanced a proposal for a registry of vendors that supply AI models and datasets to insurers. It is described as registration, not licensing, but it signals closer scrutiny of the companies behind underwriting and pricing models.
Some states have gone further on their own. Colorado, for example, has governance and testing requirements for life insurers that use external consumer data.
What this means if you sell
These rules are aimed at carriers, not at individual agents. They still reach you in practical ways.
- Expect more questions from carriers about the tools you use to market, quote, and communicate.
- Automated underwriting decisions will need explanations. As carriers document their models, you should get clearer reasons when an accelerated decision goes against your client.
- Keep a person responsible for what AI says on your behalf. If an AI tool texts or answers calls for you, you are still the licensed professional answerable for what the client was told.
- Be accurate about AI in your marketing. Describe what your tools do, and do not imply that software makes coverage decisions.
The agents who do well with AI will be the ones who use it to respond faster and stay organized, while keeping judgment and advice with the licensed person.