AI FOR US INSURANCEAI for US insurance: faster submissions without tripping the state AI rules

What do we build for US MGAs, agencies and carriers?

We build the AI behind the front end:

• Submission intake: reads ACORD forms, schedules and loss runs, extracts every field, and shows where each value came from. Venus Pro does this, with a working Applied Epic integration.
• Multi-carrier quoting: one submission to several carriers, with quotes compared side by side.
• Carrier product configuration: turns carrier documents into structured, API-ready product definitions, so products can be quoted without hard-coding. Nexus digitised a UK-based carrier with a US presence that had no APIs.
• Bordereaux and reconciliation: we have delivered bordereaux automation and commission reconciliation for insurance clients.
• Policy, underwriting and claims platforms: API-first, from quote to first notice of loss (FNOL) and settlement.

For a US insurance services firm, Quantana is delivering a 15-module AI submission and quoting platform and a 28-module configuration and underwriting workbench, contracted from July 2026. [1] Read the case study.

For the full playbook, including bordereaux and reconciliation, read our guide to AI for MGAs and insurance agencies.

What are the US rules for AI in insurance?

There is no single federal AI law for insurance. Insurance is regulated by the states, and the states have moved.

The NAIC Model Bulletin

The National Association of Insurance Commissioners (NAIC) adopted its Model Bulletin on the Use of Artificial Intelligence Systems by Insurers on 4 December 2023. [2] It expects insurers to have a written program for the responsible use of AI systems, covering governance, risk management, testing and oversight of third-party vendors, across the insurance lifecycle.

As at 3 November 2026, the NAIC lists 29 jurisdictions as having adopted it: Alaska, Arkansas, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Iowa, Kentucky, Maryland, Massachusetts, Michigan, Mississippi, Nebraska, Nevada, New Hampshire, New Jersey, North Carolina, North Dakota, Oklahoma, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, Vermont, Virginia, Washington, West Virginia and Wisconsin. [2]

The same NAIC map lists four states with their own insurance-specific AI regulation or guidance instead: California, Colorado, New York and Texas. [2] The NAIC has also piloted an AI Systems Evaluation Tool with 12 states during 2026, for use in market conduct exams. [3]

New York: DFS Circular Letter No. 7 (2024)

The New York State Department of Financial Services (DFS) issued Insurance Circular Letter No. 7 on 11 July 2024. [4] It covers AI systems and external consumer data used in underwriting and pricing. In plain terms, it expects insurers to:

• show that external data has a clear, statistically supported link to risk and is not a proxy for a protected class;
• test for unfair discrimination before production, regularly afterwards and after material changes, and look for less discriminatory alternatives;
• keep board oversight, written policies reviewed at least annually, and internal audit coverage;
• stay responsible for vendor tools, with their own due diligence and audit rights in contracts;
• explain adverse decisions specifically, without hiding behind a vendor’s proprietary algorithm. [4]

Colorado: SB21-169 and Regulation 10-1-1

Colorado’s SB21-169 targets unfair discrimination from external consumer data and predictive models. Its governance rule, Regulation 10-1-1 (3 CCR 702-10), first applied to life insurers from November 2023. [2] An amended version, effective 15 October 2025, extends the governance and risk management framework to private passenger auto and health benefit plan insurers. [5]

California: Bulletin 2022-5, SB 1120 and the CCPA rules

The California Department of Insurance issued Bulletin 2022-5 on 30 June 2022, warning all insurers and licensees about bias and unfair discrimination from algorithms and big data in marketing, rating, underwriting and claims. [2][6] For health, SB 1120 limits how AI can be used in utilisation review; the Department issued guidance on it on 5 May 2025. [7] Separately, the California Privacy Protection Agency’s rules on automated decision-making technology apply to significant decisions from 1 January 2027. [8]

Texas: TDI and TRAIGA

The Texas Department of Insurance (TDI) issued Bulletin B-0036-20 on 30 September 2020. [2] The Texas Responsible Artificial Intelligence Governance Act (HB 149) took effect on 1 January 2026. It says it does not authorise any agency other than TDI to regulate the business of insurance, and its discrimination section does not apply to insurers already subject to insurance unfair discrimination laws. [9]

The federal question

Executive Order 14365 of 11 December 2025 seeks a national AI framework and challenges some state AI laws. The NAIC responded that insurance oversight sits with the states. [10] Plan to the state rules.

General information, not legal advice. As at 8 Nov 2026.

What this means for an MGA or agency: these rules mostly bind carriers. But carriers stay responsible for AI used on their business, including by agents and vendors, so expect the questions in your next carrier audit. [4]

What about data privacy: GLBA and state laws?

Insurance data is financial data.

• GLBA. The Gramm-Leach-Bliley Act requires financial institutions, including insurers and agencies, to protect customer information and give privacy notices. For insurance, GLBA’s privacy rules are enforced by state insurance regulators. [11]
• NAIC Insurance Data Security Model Law (#668). Adopted in many states, it requires an information security program and notification of cybersecurity events to the insurance commissioner. [12]
• New York 23 NYCRR 500. The final phase of the amended DFS cybersecurity regulation took effect on 1 November 2025, including multi-factor authentication for anyone accessing a covered entity’s information systems and a complete asset inventory. [13]
• California CCPA. Personal information covered by GLBA is largely outside the CCPA, but other data an insurer or agency holds may not be. Check your position with counsel. [8]

For AI, the practical point is simple: know where every document goes. If submissions are processed by an AI model, your vendor terms should say where the data is stored and processed, who can see it, and that it is not used to train someone else’s model. Our private AI guide covers on-premises and private cloud options.

Which US insurance markets feel these rules most?

Our US company, Quantana LLC, is in San Ramon, California, in the San Francisco Bay Area. Below are five US insurance markets and the specific reason each matters for AI. They are markets we follow, not offices.

San Francisco and the Bay Area. California is the largest surplus lines market in the US: $22.1 billion of premium in 2025, up 5.7 per cent. [14] It also has its own insurance AI guidance (Bulletin 2022-5) and privacy rules on automated decisions from 2027. [6][8] An AI tool built for California has to be explainable from day one.

San Diego. San Diego accounted for 5.3 per cent of California’s excess and surplus (E&S) homeowners placements in 2025, second only to Los Angeles among the state’s cities, as more than 300,000 homeowners policies moved to surplus lines. [15] That shift means more submissions, more property schedules and more carriers per risk: exactly the intake and quoting work AI handles.

New York. New York is home to DFS, whose Circular Letter No. 7 is the most detailed state guidance on AI in underwriting and pricing, and whose cybersecurity regulation applies to licensed agents and brokers too. [4][13] Surplus lines business placed in New York goes through the Excess Line Association of New York (ELANY), so E&S brokers there carry an extra layer of filing on every placement. [16]

Philadelphia. Philadelphia is where US stock insurance started: Chubb’s oldest subsidiary, INA, was founded in 1792 at Independence Hall. [17] Pennsylvania adopted the NAIC AI bulletin in April 2024, and its surplus lines premium grew 16.2 per cent in 2025, among the fastest in the country. [2][14]

Austin. Austin is home to the Texas Department of Insurance, [18] which regulates the second-largest surplus lines state: Texas wrote $18.2 billion of surplus lines premium in 2025, up 9.8 per cent. [14] Texas also now has its own AI statute, with insurance left to TDI. [9]