--- title: "NAIC AI Model Bulletin Compliance: A Complete Guide for Insurance Agents (2026)" description: "Everything insurance agents and agencies need to know about the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers — adoption status, governance requirements, and CRM-level controls." url: https://unlockedcrm.ai/blog/naic-ai-model-bulletin-compliance-guide canonical: https://unlockedcrm.ai/blog/naic-ai-model-bulletin-compliance-guide category: "Compliance & Regulatory" published: 2026-01-15 updated: 2026-01-15 author: "unLocked Compliance Team" source: unLocked CRM — AI CRM for insurance agents --- # NAIC AI Model Bulletin Compliance: A Complete Guide for Insurance Agents (2026) ## TL;DR The NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers (adopted December 2023) has been adopted by 25+ states as of January 2026. It requires insurers and producers to maintain a written AIS Program covering governance, risk management, third-party AI oversight, testing, and consumer protection. Producers using AI tools (including AI-powered CRMs, voice agents, and underwriting assistants) must verify their carriers' AIS Programs and document their own AI usage, bias testing, and adverse action procedures. # NAIC AI Model Bulletin Compliance: A Complete Guide for Insurance Agents **Updated January 15, 2026.** Reflects the latest state adoption status and 2026 enforcement priorities. ## What Is the NAIC AI Model Bulletin? The **Model Bulletin on the Use of Artificial Intelligence Systems by Insurers** was adopted by the NAIC on **December 4, 2023**. It establishes the framework that state regulators are using to govern AI in the insurance industry. As of January 2026, **25+ states have formally adopted the Bulletin**, with California and New York expected to follow in 2026. ## What the Bulletin Requires Every covered insurer (and, by extension, producers using AI) must maintain a written **AI Systems Program (AIS Program)** containing: 1. **Governance** — board/senior leadership oversight, written policies, defined roles 2. **Risk Management** — pre-deployment risk assessment, ongoing monitoring 3. **Third-Party AI Oversight** — due diligence on vendors (including CRM, voice AI, and quoting tools) 4. **Testing & Validation** — bias testing, accuracy monitoring, drift detection 5. **Consumer Protection** — adverse action notices, explainability, complaint handling 6. **Documentation** — training data sources, decision logic, audit trails ## What This Means for Insurance Producers While the Bulletin is primarily aimed at carriers, **producers are increasingly in scope** because they: - Operate AI-powered CRMs (autonomous outbound, voice agents) - Use AI underwriting assistants and policy analyzers - Trigger marketing and quoting workflows that materially affect consumers **Producer obligations include**: - Verifying that AI vendors (CRM, voice AI, quoting tools) have governance frameworks - Documenting which AI tools are used and for what - Disclosing AI involvement when AI materially influenced an adverse outcome - Maintaining audit trails for state DOI examinations ## How a Modern Insurance CRM Helps A NAIC-aligned CRM (like unLocked) provides: - **Built-in AI governance documentation** — exportable for DOI exams - **Decision audit trails** for every AI-driven action (outbound, quote, recommendation) - **Bias monitoring dashboards** for outbound targeting and lead scoring - **Adverse action templates** with AI-disclosure language - **Vendor due diligence packages** for downstream AI tools ## State Adoption Status See the comparison table above for the current adoption matrix. Key 2026 watch items: - **California** — expected to add stricter bias-testing requirements - **New York** — likely to issue a standalone framework via Circular Letter - **Florida & Georgia** — under active review ## Bottom Line The NAIC AI Model Bulletin has gone from advisory to operational reality. Producers using AI without an AIS Program are increasingly exposed to DOI enforcement actions, market conduct exams, and E&O claims. A NAIC-aligned CRM converts this from a compliance burden into a documented, auditable workflow. ## FAQ ### undefined ### undefined ### undefined ### undefined ## Related - https://unlockedcrm.ai/blog/state-by-state-ai-disclosure-laws-insurance - https://unlockedcrm.ai/blog/tcpa-2026-updates-insurance-dialing - https://unlockedcrm.ai/blog/hipaa-compliant-crm-checklist --- Source: [NAIC AI Model Bulletin Compliance: A Complete Guide for Insurance Agents (2026)](https://unlockedcrm.ai/blog/naic-ai-model-bulletin-compliance-guide) — unLocked CRM, the AI CRM built for insurance agents. Citation permitted with attribution and a link to https://unlockedcrm.ai/blog/naic-ai-model-bulletin-compliance-guide.