AI regulation in insurance, the current map.
The NAIC model bulletin count moved again this quarter, and the NAIC's AI Systems Evaluation Tool is in a 12-state pilot reported at the Spring 2026 national meeting on March 24, 2026, with revisions expected to follow the pilot. Here is the map as it stands, dated and sourced.
Dated on purpose
Every count and row on this page names its source and the date we checked it. The NAIC's own implementation map changed between our June 12 and July 2, 2026 retrievals without changing its printed status date. That is the pace of this space, and it is why an undated adoption count is quickly wrong.
51 jurisdictions, four buckets
24 states plus the District of Columbia have adopted the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, or substantially similar guidance.
California, Colorado, New York, and Texas issued instruments of their own, from a 2020 bulletin to a fully binding regulation.
West Virginia was listed by law-firm trackers while absent from the NAIC map when we checked on June 12, 2026. It is on the map as of our July 2, 2026 check.
The remaining 22 jurisdictions show no instrument on the NAIC map today. Watch-list material, not silence.
Source: NAIC, "Implementation of NAIC Model Bulletin: Use of Artificial Intelligence Systems by Insurers" map, status as of April 1, 2026, retrieved July 2, 2026. Our June 12, 2026 retrieval of the same map listed 24 jurisdictions (23 states plus the District of Columbia); West Virginia has since been added without a change to the map's status date. Evaluation Tool pilot: NAIC Big Data and Artificial Intelligence Working Group meeting of March 24, 2026, as summarized by Mayer Brown, April 2026.
Six rows that show why the dates matter
Adoption is not one thing. Some jurisdictions took the model bulletin as written, some wrote something stricter years earlier, and one spent most of 2026 listed differently depending on whom you asked.
| Jurisdiction | Instrument | Date | Status | Note |
|---|---|---|---|---|
| Texas | TDI Commissioner's Bulletin B-0036-20 | 2020-09-30 | Own guidance | The oldest instrument on the NAIC map, issued three years before the model bulletin existed. |
| California | CDI Bulletin 2022-5 | 2022-06-30 | Own guidance | Predates the model bulletin; California has issued no model-bulletin adoption since. |
| Colorado | 3 CCR 702-10, under SB 21-169 | 2023-11-13 | Own regime | A full binding regulation, not a bulletin. Amendments effective October 15, 2025 extend it to private passenger auto and health benefit plan insurers. |
| New York | Insurance Circular Letter No. 7 (2024) | 2024-07-11 | Own regime | More prescriptive than the model bulletin: ECDIS assessments, proxy analysis for protected classes, and board-level oversight. |
| Hawaii | Insurance Commissioner Memorandum No. 2025-13A | 2025-12-10 | Adopted | Adopted the model bulletin. The newest adoption on the NAIC map. |
| West Virginia | Insurance Bulletin No. 24-06 | 2024-08-09 | Dispute resolved | Listed as an adoption by law-firm trackers while absent from the NAIC map as retrieved June 12, 2026; present on the map as retrieved July 2, 2026. Catching that gap, and its closure, is what the matrix is for. |
Six rows are the teaser. The matrix is part of the product.
Castle maintains the full 51-jurisdiction matrix, all 50 states plus the District of Columbia: every instrument, status, primary source, and retrieval date, a watch-list of items that could change the map, and per-jurisdiction preparation notes for the states where you write business. Every record carries the source it was verified against and the date we verified it.
When a tracker and the primary source disagree, the matrix says so instead of picking the convenient answer. West Virginia above is what that looks like in practice.
Watched by software, ratified by a person, both dates on every citation
The West Virginia row above is what happens when a regulator edits a document in place: the NAIC map added a state without changing the status date printed on page one. Castle now watches for exactly that. Each source on the watch list (the NAIC map, the working-group and exposure-draft pages, the Colorado, New York, and Connecticut department pages) is retrieved on its documented cadence, stored as a content-addressed snapshot, and compared as text with the previous retrieval. A change under an unchanged printed date is reported as its own fact, not inferred.
A change becomes a candidate proposal naming the source, the printed as-of date, the retrieval date, the diff, and the exact records to re-verify. No model decides whether it matters and nothing updates the matrix on its own. A named person accepts, rejects, or amends the proposal, and that decision is recorded on the tamper-evident chain with both dates and both content digests. The freshness check that ages this matrix then prefers the ratified observation over the shipped stamp and says which one it used.
Built and tested August 2026. It has not yet run against the NAIC revision expected in September and October 2026; the "last verified" date below is still the July 2 human retrieval, and it will move when a person ratifies the next one.
Last verified July 2, 2026, against the NAIC implementation map (status as of April 1, 2026) and the state instruments named above. Regulatory summaries are for orientation, not legal advice.