Which states have adopted the NAIC AI Model Bulletin, with bulletin numbers and dates

If your company is licensed in any state below, that state's regulator expects a written AI systems program and may ask for its documentation. Twenty-five states and the District of Columbia had adopted the NAIC Model Bulletin as of August 31, 2026; four more states regulate AI in insurance under rules of their own.

Adopting states

Pennsylvania's version is the one this site covers in detail: the Notice 2024-04 documentation checklist. Wisconsin's bulletin carries no number on the NAIC map. Nebraska issued guidance rather than a bulletin.

States with their own AI rules instead

What adoption means in practice

Each adopting state's instrument tracks the NAIC Model Bulletin: insurers that use AI systems, including AI embedded in vendor rating, claims or fraud tools, are expected to keep a written AI systems program covering governance, risk management and internal audit, and can be asked for that program and its documentation in an examination. The wording is "expected" and "may request"; the bulletins say they create no new requirements. Twelve of these states piloted the NAIC's examiner evaluation tool from March to September 2026.

A company licensed in several of these states answers the same questions once; the documentation list is the same list. The Evidence Pack scores it in one pass.

Source

• NAIC, "Implementation of NAIC Model Bulletin: Use of Artificial Intelligence Systems by Insurers," status as of August 31, 2026 (PDF): content.naic.org. Read October 6, 2026.

Related

• Pennsylvania Insurance Notice 2024-04: the AI documentation checklist
• The NAIC AI Model Bulletin: what it expects insurers to keep
• What "Not evidenced" means, and why it is scored like a gap
• How to verify an AI decision log, and prove nobody edited it
• The AI Workflow Evidence Pack: find out which of these you can evidence today, from one decision-log export.