Please take note of the following December 2025 developments in the insurance industry.
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This article provides an excellent overview of the challenges insurers face in drafting policy language that keeps pace with the fast-evolving use of artificial intelligence. The author discusses how multiple insurers faced the challenge of defining what is “artificial intelligence” or “generative AI” by consulting with various industry sources. I asked ChatGPT how it would…
On August 20, 2025, the Colorado Division of Insurance (Division) amended Regulation 10-1-1 to expand its existing limited applicability to insurers offering individual life insurance to apply to insurers offering private passenger auto and health benefit plans effective October 15, 2025. Evidence of compliance with the amended regulation must be made available to the Division…
The insurance industry is facing increased scrutiny from insurance regulators related to its use of artificial intelligence (AI). Red teaming can be leveraged to address some of the risks associated with an insurer’s use of AI. The U.S. Department of Commerce’s National Institute of Standards and Technology (NIST) defines a “red team”[1] as:…
On July 7, 2025, Pennsylvania Governor Josh Shapiro enacted a new Digital Forgery Law by signing SB 649 into law, which will take effect in 60 days. SB 649 creates “new criminal penalties for anyone who uses artificial intelligence (AI) to produce non-consensual “forged digital likenesses” — like deepfakes or voice clones — to defraud or…
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…
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.…
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…
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 Delaware Department of Insurance’s authority to…
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.
Read the Oklahoma Bulletin.
The…
