Illinois insurance AI regulation

Illinois has adopted the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, via Company Bulletin 2024-08, adopted 2024-03-13.

Details

Jurisdiction	Illinois (IL)
NAIC model bulletin	Adopted
Citation	Company Bulletin 2024-08
Date	2024-03-13 (adopted)
Source	Implementation of NAIC Model Bulletin: Use of AI Systems by Insurers, as of 2026-08-06

Other AI-related insurance activity

Measure

Status

SB 3114, Public Act 104-0568, Transparency in Downcoding Act Bars automated downcoding of medical claims: every downcoding determination must be made or reviewed by a natural person following coding guidelines. Also bars payors from using downcoding in a targeted or discriminatory manner against health care professionals treating complex conditions, and requires physicians be clearly notified when a claim is downcoded. made or reviewed by a natural person source

enacted, effective 2028-01-01 ✓ verified against the source text

Context

Of 51 tracked US jurisdictions, 25 have adopted the NAIC model bulletin, 4 run their own insurance-specific AI framework (California, Colorado, New York and Texas), and 22 have not adopted it but have other tracked AI-related insurance activity. The bulletin restates that existing unfair trade practice and unfair discrimination law applies to AI-driven decisions; it does not create new statutory obligations.

Two tracks. Insurance AI regulation runs on two largely independent tracks: the NAIC model bulletin (governance, all lines), and a 2026 wave of health-insurance statutes restricting AI as the sole basis for claim or coverage denial. A state can be active on the second while absent from the first. Absence from the NAIC map is not absence of regulation.

See all 51 jurisdictions · This record as JSON