There is a proposed 10-year moratorium on the enforcement of state laws that regulate artificial intelligence (AI) contained in Section 43201(c) of H.R.1 – One Big Beautiful Bill Act. The National Association of Insurance Commissioners (NAIC) recently submitted its response to members of the U.S. Senate (attached at the link), raising various concerns that the moratorium will have unintended consequences, including:

Paige Waters
Paige brings extensive experience in insurance and reinsurance law, handling transactional, regulatory, and insolvency matters for national and international clients.
Wisconsin Becomes the 24th State to Adopt the NAIC Model Bulletin on the Use of AIS in Insurance
On March 18, Wisconsin Insurance Commissioner Nathan Houdek issued Wisconsin’s new bulletin on the use of artificial intelligence systems (AIS) in insurance, becoming the 24th state to adopt the NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers. A copy of the bulletin is found at this link.
NAIC Establishes the Risk-Based Capital Model Governance (EX) Task Force in 2025
The 2025 National Association of Insurance Commissioners (NAIC) President and North Dakota Insurance Commissioner Jon Godfread has stated that:
“As state insurance regulators and NAIC Members, our efforts are anchored by two core principles: maintaining fair, sound, and stable insurance markets, and protecting and educating consumers.”
New Jersey Adopts Bulletin on AI Use in Insurance
On February 11, New Jersey Banking and Insurance Commissioner Zimmerman issued Bulletin 25-03 regarding the use of artificial intelligence systems (AIS) in insurance, applicable to all insurers authorized or admitted in New Jersey. New Jersey becomes the 23rd state to adopt the bulletin based on the NAIC Model Act on the Use of AIS by Insurers.
Delaware Insurance Commissioner Navarro Issues Bulletin No. 148 Re: Use of Artificial Intelligence Systems in Insurance
On February 5, Delaware joined 21 jurisdictions who adopted guidance similar to the NAIC Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers in 2024, and four additional jurisdictions have otherwise issued guidance or regulation.
In addition to other detailed guidance, Bulletin No. 148 also reiterates the…
Hawaii Insurance Commissioner Gordon Ito Retired Effective January 31, 2025
On February 3, the Hawaii Insurance Division issued a press release stating that Insurance Commissioner Gordon Ito has retired as of January 31. Ito served in the division for 31 years in various capacities, including as commissioner for 10 years. He also served under four Hawaii governors and was most…
Oklahoma Issued Bulletin 2024-11: Use of Artificial Intelligence Systems in Insurance
On November 14, 2024, Oklahoma issued Bulletin 2024-11: Use of Artificial Intelligence Systems in Insurance. The Bulletin is applicable to all insurers that hold a certificate of authority to do business in the state and is based upon the NAIC Model Bulletin on the Use of AIS by Insurers.…
NY DFS Issues an Industry Letter Regarding AI Cyber Guidance
On October 16, 2024, the NY DFS issued an Industry Letter that explaining “how Covered Entities should use the framework set forth in Part 500 to assess and address the cybersecurity risks arising from AI.”…
Iowa Insurance Division Releases Proposed AI Bulletin for Comment
On October 10, 2024, the Iowa Insurance Division released for comment a proposed AI Bulletin based upon the NAIC AI Model Bulletin.…
You’re Invited: Complimentary 2024 Insurance Forum
2024 Insurance Forum
October 30, 2024 / 9:00 AM -3:30 PM
Offices of Locke Lord LLP, 111 S. Wacker Drive, 41st Floor, Chicago, IL 60606
In Person Only
Locke Lord is proud to sponsor and host the 2024 Insurance Forum in the Chicago office on October 30. Paige Waters will…