What does the NAIC AI model bulletin require of an independent agency?
Directly, nothing: the bulletin is written to insurers. In practice three of its expectations land on your desk, and carriers are starting to write them into their contracts.
Answered in short
5 things that decide this
- 01The NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers was adopted on December 4, 2023. It is addressed to 'all Insurers licensed to do business' in the adopting state, so an independent agency is not its addressee.
- 02About 25 states had adopted the bulletin by mid-2026. California, Colorado, New York and Texas run their own AI rules instead, so the rule that reaches your agency depends on where your customers live.
- 03An agency inherits the bulletin's duties as a 'Third Party'. The bulletin uses that term for any company other than the insurer that provides AI services, data or resources. It expects carriers to vet those companies and to write audit rights into their contracts.
- 04The bulletin creates no new law. It applies the state's unfair trade practices law to AI-assisted decisions, and that law already binds producers directly.
- 05Section 1.9 expects a process for telling consumers that AI systems are in use. The carrier owns the program, but you are usually the desk the consumer talks to, so the notice and the record of it land on you.
What the bulletin says, and who it says it to
Each state department issues the NAIC bulletin in its own name, to the insurers it licenses. It tells them that AI-assisted decisions must comply with existing insurance law. It expects a written program, called an AIS Program, covering governance, risk controls and internal audit. And it lists what an examiner may ask for, whether or not the insurer ever wrote that program down.
Nothing in the text names producers or agencies. One word in it reaches you: 'Third Party'. Section 4 of the guidelines expects each insurer to vet the AI systems it gets from others before use. It expects contract terms that give the insurer audit rights. And it expects the third party to cooperate with regulator questions about the insurer's use of its product.
Does your agency run an AI quoting tool, a triage bot or a renewal model that shapes what a carrier sees? Then you fit that definition. Expect the questionnaire, the contract clause and, in time, a request for records during a carrier's exam.
The three duties that land on an agency
First, records you can hand a carrier. The exam section lets a regulator ask an insurer for proof that it vetted, watched and audited third-party AI. A carrier that can't answer for your tool will ask you for the record, or stop sending you business. Keep an inventory of every AI touchpoint at your agency, and a log of human review on each AI-assisted quote.
Second, the consumer notice. Section 1.9 expects processes 'providing notice to impacted consumers that AI Systems are in use'. In an agency model the consumer hears from you, not the carrier. A plain sentence in your quote letter, matched to your state's version of the bulletin, is the practical shape. Our sibling page on customer disclosure covers the wording.
Third, the law underneath it. The bulletin rests on the Unfair Trade Practices Act and the Unfair Claims Settlement Practices Act. It says AI-assisted decisions must not be 'inaccurate, arbitrary, capricious, or unfairly discriminatory'. Those statutes already govern producers. If your AI tool steers a customer badly, you answer under them today, bulletin or not.
You don't have to invent this record-keeping shape. PremiumAudit.io, an insurance audit platform Hashlogics built, put carriers, auditors and policyholders on one shared record instead of traded spreadsheets. Its AI parses documents and checks calculations under human review. An agency's AI log is the same idea pointed at compliance. You create it when the tool runs, and a carrier or examiner can read it with no scramble.
- InventoryEvery tool that scores, quotes or triages.
- Diligence fileVendor terms, data use, audit rights.
- Human reviewLicensed person before release.
- Consumer noticeMatched to the state's rule.
- Log keptWhat the carrier's examiner asks for.
The bulletin binds the carrier. The record it asks for is built at your desk.
Related questions
01Does the NAIC bulletin apply to insurance agents directly?+
No. The model bulletin is addressed to licensed insurers. Your agency is reached as a third party the insurer must oversee. It is also reached through the state unfair trade practices law the bulletin relies on, which already applies to producers.
02Do we need our own AIS Program?+
Not under the bulletin's text, which asks insurers to write one. You do need the pieces a carrier will ask you for. Those are an inventory of AI tools, a human review record, a consumer notice process, and vendor terms you can produce. With those in hand, a carrier's diligence questionnaire is a copy-and-paste job.
03What if our state hasn't adopted the bulletin?+
The unfair trade practices law still applies to every quote you issue, with or without AI. California, Colorado, New York and Texas have their own AI rules, and a multi-state book can cross several regimes in one day. Build the record once and map the notice wording per state.
Related
- Do customers have to be told AI was used in their quote? →The consumer-notice half of the same bulletin.
- Does an agency's E&O policy cover AI quoting errors? →The liability question the bulletin sits next to.
- Software for insurance agencies →Our insurance hub: what agencies actually build.
- Business process automation →The service behind capture-when-it-happens records.
