State AI Compliance

What does Texas TDI Bulletin B-0003-26 require?

← All answers

Texas Department of Insurance Bulletin B-0003-26, issued June 12, 2026, expects regulated entities and their agents and representatives to keep AI-assisted decisions compliant with existing insurance law, maintain controls that reduce the risk of bad outcomes for consumers, have “a person to review and agree with all decisions before action is taken” where AI drives something consequential, and maintain governance, risk-management, data and privacy protections, and internal controls they can describe to TDI on request (TDI, Bulletin B-0003-26). It does not create a renewal attestation, a new continuing-education requirement, a prescribed policy template, or a new penalty schedule.

The qualifier: B-0003-26 is expectations, not a form. TDI says it will monitor AI use “through examinations and product filings,” and that nothing in the bulletin limits its existing authority to investigate, examine, or take enforcement action under current law. The obligation is being able to describe real controls when asked — not filing a specific document.

What B-0003-26 requires — and what it doesn’t

ProvisionIn the bulletin?Detail, per the bulletin text
Applies to agentsYesScope is "all regulated entities and their agents and representatives," extending "to any third party working with a regulated entity"
Human review of consequential AI decisionsYes"A person to review and agree with all decisions before action is taken"
Governance frameworkYesGovernance, risk management, data and privacy protections, and internal controls — describable to TDI on request
Compliance with existing insurance lawYesAI-assisted decisions must satisfy the same unfair-trade-practice and market-conduct law as human ones
License-renewal AI attestationNoNot in the bulletin text; no AI item on TDI's agent continuing-education page either
AI-specific CE requirementNoTDI's continuing-education page (tdi.texas.gov) lists none
Prescribed template or formNoExpectations only — no required document format
New penalty scheduleNoEnforcement runs through TDI's existing exam, filing, and enforcement authority

Source for every row: TDI Bulletin B-0003-26 (issued June 12, 2026) and TDI’s Agent Continuing Education page, both at tdi.texas.gov.

Where it fits

B-0003-26 is Texas’s second AI-adjacent bulletin, joining B-0036-20 (September 30, 2020), which made insurers accountable for the accuracy of third-party data used in rating, underwriting, and claims. Texas has never adopted the NAIC’s model bulletin: per the NAIC’s implementation map (status as of April 1, 2026), it is one of four states — with California, Colorado, and New York — running its own framework while 24 states plus D.C. adopted the NAIC model. The NAIC model is the more prescriptive of the two — its written “AIS Program” structure is unpacked in What is the NAIC AI Model Bulletin? — and it makes a useful template for satisfying Texas’s shorter bulletin.

For the full walkthrough — the renewal-attestation rumor and where it came from, the two-bulletin history, and a one-page AI governance policy a Texas agency can write in an afternoon — see Texas TDI’s AI Bulletin: What B-0003-26 Really Requires.

Related questions

Both. The bulletin's own text applies its expectations to 'all regulated entities and their agents and representatives,' and says they 'extend to any third party working with a regulated entity.' A Texas-licensed agent using AI tools in work for or with a carrier is inside its scope.
No. That claim circulates in agent group chats, and it is not in the bulletin. B-0003-26, read directly from tdi.texas.gov, contains no renewal-application attestation, and TDI's agent continuing-education page lists no AI-specific CE requirement either.
No. Per the NAIC's implementation map (status as of April 1, 2026), Texas is one of four states — with California, Colorado, and New York — that regulate insurer AI through their own framework. Texas's is TDI Bulletin B-0036-20 (September 30, 2020) on third-party data accuracy, now paired with the AI-specific B-0003-26 (June 12, 2026).
The bulletin creates no new fine schedule. It states TDI will monitor AI use through examinations and product filings, and that nothing in it limits TDI's existing authority to investigate, examine, or take enforcement action. The practical exposure is having nothing to show when an exam or filing review asks how your AI-assisted work is governed.

Sources

  1. Texas Department of Insurance — Bulletin B-0003-26, Use of Artificial Intelligence (June 12, 2026) — tdi.texas.gov
  2. Texas Department of Insurance — Bulletin B-0036-20, Insurers' Use of Third-Party Data (Sept. 30, 2020) — tdi.texas.gov
  3. Texas Department of Insurance — Agent Continuing Education — tdi.texas.gov
  4. NAIC — Implementation of NAIC Model Bulletin (status as of Apr. 1, 2026) — content.naic.org

Every number on this page names its source and date. Browse all answers or the fuller discussions on the blog. Tech Savvy Insurance is a training and software community — not an insurance company, agency, or law firm — and does not provide insurance, legal, tax, or compliance advice. You are responsible for your own licensure and for complying with all applicable CMS, HIPAA, state, and carrier regulations.