Which states have adopted the NAIC AI Model Bulletin?

24 states plus the District of Columbia — 25 jurisdictions total — have adopted the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers, according to the NAIC’s own implementation map, status as of April 1, 2026 — the most recent version the NAIC has published as of August 17, 2026. Four more states — California, Colorado, New York, and Texas — regulate insurer AI through their own insurance-specific frameworks instead of adopting the NAIC’s model language, which leaves 22 states with no formal AI-specific insurance guidance on that map.

One qualifier before the table: the NAIC’s map “represents state action or pending state action addressing the topic of the model” and does not certify that each state’s version contains every element of the model bulletin. Adoptions also continue — so treat the table below as complete through April 1, 2026, and check the NAIC map (linked in the sources) for action after that date.

Every adopting jurisdiction, with bulletin number and date

Source for every row: NAIC, Implementation of NAIC Model Bulletin: Use of Artificial Intelligence Systems by Insurers, reference list, status as of April 1, 2026.

The four states with their own framework instead

The pace tells the story: 15 jurisdictions adopted in 2024, four in 2025, starting with Alaska in February 2024 and most recently Hawaii in December 2025. The bulletin itself — what an “AIS Program” is and what adopting states now expect — is covered in What is the NAIC AI Model Bulletin?, and Texas’s own separate path is covered in What does Texas TDI Bulletin B-0003-26 require?. For what adoption means in practice for a Health & Life agency — liability, CMS’s Medicare marketing rules, and a governance framework you can actually run — see our full guide to AI compliance for insurance agents in 2026.