Insurance AI Compliance
Trustible separately covers Colorado insurance guidance (Reg 10-1-1), NYDFS guidance, and the NAIC Model Bulletin.
What Each Framework Requires
How Trustible Supports Insurance AI Governance
US Insurance FAQs
As of mid-2026, 25 states plus the District of Columbia have formally adopted the NAIC Model Bulletin, with several more actively moving through legislative or regulatory approval. California, Colorado, New York, and Texas have taken a different route, operating under their own insurance-specific AI frameworks rather than adopting the Bulletin directly. States that haven't formally adopted it are increasingly applying its principles through market conduct examinations regardless, so the practical reach extends further than the formal adoption count suggests. For a multi-state carrier, most of the country now has some form of AI governance expectation on the books, and building to NAIC standards positions you well ahead of where the remaining states are heading.
No, they're two separate laws with different scope. SB 21-169 (implemented through Regulation 10-1-1) is insurance-specific, governing how insurers use external consumer data, algorithms, and predictive models in regulated decisions like underwriting and pricing. The Colorado AI Act (SB 26-189) is the broader law, extending high-risk AI consumer protections across sectors including employment, education, healthcare, and financial services, not just insurance. An insurer operating in Colorado is likely subject to both: SB 21-169 for insurance-specific obligations and annual certification, and the Colorado AI Act for any high-risk AI use that falls outside insurance-specific activity, like an internal hiring tool. Organizations that have built governance programs for SB 21-169 will find significant overlap with the AI Act's requirements, since both share the same underlying activities of risk assessment, bias testing, and documentation.