NAIC AI model bulletin adoption map: 29 jurisdictions, one by one

The NAIC AI model bulletin adoption map is the NAIC Legal Division's one-page record of which states have acted on its Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, adopted on 4 December 2023. In its status of 8 October 2026 it lists 29 jurisdictions that adopted the model, 27 states plus the District of Columbia and Puerto Rico, and four states with insurance-specific rules or guidance of their own: California, Colorado, New York and Texas. The count is 29 jurisdictions, not 29 states. For a multi-state carrier each of those 29 is a separate document with its own number and date, mostly the model's text and sometimes not, and each must be compared with what the carrier already implemented. Botminds' Regulatory Change Management for Insurers does that comparison when each adoption is published, which is the work this map creates.

Everything on this page about adoptions comes from the NAIC map and the regulators' own documents, linked where they appear. Product examples are sample data on a fictional carrier.

How many states have adopted the NAIC AI model bulletin?

As of 8 October 2026, 29 jurisdictions had adopted the NAIC AI model bulletin, according to the NAIC's map: 27 states, the District of Columbia and Puerto Rico. Four further states, California, Colorado, New York and Texas, appear separately with insurance-specific regulation or guidance that is not an adoption of the model. Counting all of them gives 33 jurisdictions with some AI-specific insurance instrument on the map; counting only states that adopted the model gives 27.

The distinction between states and jurisdictions is not pedantry. The NAIC's members are "the chief insurance regulators from the 50 states, the District of Columbia, and five U.S. territories" (NAIC), so its maps count all 56. A carrier writing in Puerto Rico has a 29th adoption to implement; one writing only on the mainland has 27 state adoptions and, if it writes there, the District's.

The most recent adoptions on the map are North Dakota's Bulletin 2026-2, adopted 5 October 2026, and South Carolina's Bulletin 2026-07, adopted 24 September 2026. A count published without its date goes out of date within weeks, which is why every count on this page is "as of 8 October 2026".

NAIC AI bulletin adoptions by date, 2024 to 2026

Adoption came in a rush and then a trickle. Seven jurisdictions adopted in the first quarter of 2024, within about three months of the model, and 21 had adopted by the end of 2024. Four followed in 2025 and four more in 2026 to date.

The trickle matters more to a carrier than the rush. The 2024 adoptions arrived while compliance teams were building their first AI governance programs, so each was read as part of that build. The later ones arrive one at a time, months apart, after the program is "done", and each is a chance to treat a slightly different text as a copy.

Which states have adopted the NAIC AI bulletin, and by what instrument

Twenty-three of the 29 adopted the model as something called a bulletin; the other six used a commissioner memorandum, a guidance document, a notice published in the state's register, an administrative letter, a technical assistance advisory and, in Puerto Rico, a numbered document. The table lists every adoption in date order with the instrument the map gives.

The instrument name is not trivia. A Pennsylvania notice is published in the Pennsylvania Bulletin, which is why the map cites "54 Pa.B. 1910"; a Virginia administrative letter and a Washington technical assistance advisory each sit in a different series on a different page of each department's site. A tracker that looks only for documents called bulletins will miss six of the 29.

The four states with their own AI rules: California, Colorado, New York and Texas

Four states sit on the map under "Insurance Specific Regulation/Guidance" rather than as adopters. The map gives California's Bulletin 2022-5 of 30 June 2022, New York's Insurance Circular Letter No. 7 of 11 July 2024, Texas's Bulletin B-0036-20 of 30 September 2020, and Colorado's regulation 3 CCR 702-10, "Effective November 13, 2023 (Amendments thereto effective 10/15/25)".

Colorado shows why each entry needs checking against the regulator. The Colorado Division of Insurance's own notice of adoption, dated 21 September 2023, says: "This regulation will become effective on November 14, 2023" (Colorado DOI), a day later than the map. Its amended regulation, extended to private passenger auto and health benefit plan insurers, was adopted with a notice of 20 August 2025 and "is effective on October 15, 2025" (Colorado DOI).

Texas shows why the map is a pointer, not a register. On 12 June 2026 the Texas Department of Insurance issued Commissioner's Bulletin B-0003-26, "Use of artificial intelligence", to all regulated entities. Among other things it says: "This bulletin also advises regulated entities of the type of information and documentation that TDI may request during an investigation or examination" (TDI B-0003-26). The map of 8 October 2026 still lists only the 2020 bulletin for Texas.

This map does not reflect a determination as to whether the pending or enacted legislation contains all elements of the model or whether a state meets any applicable accreditation standards.

NAIC adoption map of the AI model bulletin, status as of 8 October 2026

What the NAIC AI model bulletin adoption map does not tell you

The map records that a jurisdiction acted, with a citation and a date. It does not say what the state's text says, and the NAIC says so in the sentence above. Three things a carrier needs are therefore off the map.

What the state added or changed. Connecticut's MC-25 is on the map as an adoption of 26 February 2024. Its text adds a requirement the model does not have: "Connecticut domestic Insurers must complete the Artificial Intelligence Certification (“Certification”), which is due on or before September 1, 2024, and annually thereafter" (Connecticut Insurance Department). How states adopt NAIC model laws works through the rest of the Connecticut differences.

What came after. Texas's 2026 bulletin and Colorado's 2025 amendment are later instruments on the same subject. The first is not on the map; the second appears only as a parenthesis.

What it means for your company. Whether an adoption applies depends on where the carrier is licensed and domiciled, and which lines it writes there; Connecticut's certification falls on domestic insurers only. The map cannot know the carrier's footprint.

Puerto Rico, the District of Columbia and the territories

Two of the 29 are not states. The District of Columbia adopted the model with Bulletin 24-IB-002-05/21 on 21 May 2024, in the first wave. Puerto Rico adopted it on 11 June 2026, under a document the map cites as CN-2026-382-D, the first adoption of 2026 and, by the map, the only one among the five territories.

For a carrier writing in Puerto Rico, the practical question is the same as for any state: which sections differ from the version already implemented, and which of the carrier's paragraphs they change. The map gives the document's identifier and date, not its content, so the comparison starts from the regulator's own text. The same is true of the District's 2024 bulletin, which a carrier licensed there would have compared with the model more than two years before Puerto Rico's arrived.

The other territories, American Samoa, Guam, the Northern Mariana Islands and the U.S. Virgin Islands, do not appear among the adopters or the four insurance-specific regimes on the 8 October 2026 map.

What comes next for the NAIC AI model bulletin in 2026

Three things are moving. The NAIC's Big Data and Artificial Intelligence (H) Working Group lists among its 2026 charges to "support adoption of the Model Bulletin on the Use of AI Systems by Insurers" (NAIC working group page), so more adoptions are expected. The NAIC's AI Systems Evaluation Tool, the questionnaire examiners would use to ask about AI, was piloted by twelve states from March to September 2026, with the updated tool to be considered "for adoption at the Fall National Meeting" in November (NAIC pilot summary); it has not been adopted. And state-specific instruments keep appearing outside the model, as Texas's 2026 bulletin shows.

The model itself expects each insurer to maintain a written program for AI systems that make or support decisions in regulated insurance practices (NAIC model bulletin), set out section by section in the NAIC AI bulletin requirements. A program built once in 2024 now has to absorb each later adoption's differences, which is a regulatory change job rather than an AI governance one. Life and health carriers with European business have a separate timetable under the EU AI Act; the EU AI Act and insurance covers the high-risk classification.

Turning the adoption map into work: one row per adoption

In Regulatory Change Management for Insurers each adoption arrives as a row on the impact matrix the day the department publishes it. The Prior-adoption matcher compares it section by section with the model and with the carrier's own earlier change, marks each section new or already covered, and names the earlier change for every covered section; any wording difference counts as new. The Policy mapper drafts the change only for what is new.

One adoption, section by section: new to you, or covered by a named earlier change

On the fictional carrier's sample, an invented AI bulletin of nine sections came back with seven matched to the earlier change and two new, and the run took 18 seconds. The useful output is not the speed but the two sections: a notice to consumers and a longer retention period, each mapped to the paragraph that must change. To run the matcher on your own state adoptions, start from Regulatory Change Management for Insurers; the full trace follows the run second by second.

A lit cell: the regulator's passage beside your paragraph, with the drafted change

Questions people ask

Has California adopted the NAIC AI model bulletin?

Not according to the NAIC map of 8 October 2026. California appears with insurance-specific guidance of its own, Bulletin 2022-5 of 30 June 2022, alongside Colorado, New York and Texas.

Has Puerto Rico adopted the NAIC AI bulletin?

Yes. The NAIC map records Puerto Rico's adoption on 11 June 2026, cited as CN-2026-382-D. It was the first adoption of 2026 and, by the map, the only one among the five U.S. territories.

What changed with the NAIC AI model bulletin in 2026?

Four jurisdictions adopted it between June and 5 October 2026: Puerto Rico, Mississippi, South Carolina and North Dakota. Texas issued a new AI bulletin, B-0003-26, on 12 June 2026, and twelve states piloted the NAIC's AI Systems Evaluation Tool from March to September, with the tool due for consideration in November.

Is the NAIC AI model bulletin binding?

The model binds no one by itself; each state's version carries the force of that state's instrument. Most adopters issued it as a bulletin stating the department's expectations, and some add requirements of their own, such as Connecticut's annual certification for domestic insurers.

Where can I find the NAIC AI model bulletin adoption map?

The NAIC Legal Division publishes it as a PDF with a reference list of citations on its second page; the status line gives the date it was last updated. Check each state's own document before relying on an entry: the map does not compare texts.