New York has not adopted the NAIC model bulletin. It operates its own insurance-specific AI framework under Insurance Circular Letter No. 7, issued 2024-07-11.
| Jurisdiction | New York (NY) |
|---|---|
| NAIC model bulletin | Not adopted — own framework instead |
| Citation | Insurance Circular Letter No. 7 |
| Date | 2024-07-11 (issued) |
| Source | Implementation of NAIC Model Bulletin: Use of AI Systems by Insurers, as of 2026-08-06 |
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.