What has transpired
Timeline
A high-level chronology of the NAIC AI regulation this guide tracks. Every entry is drawn from a primary or secondary source cited on the entry; dates for pending items are Working Group statements and are not confirmed. Distinct from the changelog, which tracks changes to this guide.
- Sep 2020
Early state AI and big-data bulletins
Texas issues Bulletin B-0036-20 on the use of big data and AI, an early state-specific signal ahead of any national model.
Source: NAIC implementation map (status April 1, 2026)
- Nov 2023
Colorado adopts a governance rule for predictive models
Colorado's 3 CCR 702-10 reaches predictive models built on external consumer data, one of the first insurance-specific AI rules with teeth.
Source: NAIC implementation map; 3 CCR 702-10
- Dec 2023
NAIC adopts the Model Bulletin on the Use of AI Systems by Insurers
The national model that most states then adopt. It sets expectations for AI governance programs and for contractual terms with AI vendors, including audit rights and regulatory cooperation.
Source: NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers (Dec 2023)
- 2024–25
States adopt the model bulletin
A wave of adoptions follows. As of the April 2026 implementation map, 25 states have adopted the model bulletin and four run their own insurance-specific AI rule (California, Colorado, New York, Texas).
Source: NAIC implementation map (status April 1, 2026)
- Feb 2026
Working Group builds the evaluation tool and a pilot
The NAIC BDAI (H) Working Group develops the AI Systems Evaluation Tool (Exhibits A–D) and organizes a multi-state pilot to trial examiner inquiries.
Source: NAIC BDAI (H) Working Group minutes, Feb 2026
- Mar 2026
Supplement pilot reaches 12 states
California joins, bringing the pilot to 12 states. The pilot window runs Mar 2 to Sep 30, 2026, with per-state timing varying and some states possibly running past. Examiners in pilot states may begin sending Exhibit A inquiries.
Source: NAIC Pilot Project Summary; WG minutes Feb 2026; Fenwick, Mar 9, 2026
- Jul 2026
Draft framework for third-party data and model vendors
The NAIC circulates a draft framework for third-party vendors in P&C pricing and underwriting, adding an enforcement lever: a regulator can prohibit a model from a state if the vendor does not respond to inquiries.
Source: NAIC third-party data and model vendor framework (draft, July 2026)
- Aug 13, 2026
The tool becomes the AI Risk Evaluation Supplement
At the Summer National Meeting, the Working Group renames the AI Systems Evaluation Tool to the AI Risk Evaluation Supplement.
Source: NAIC BDAI (H) WG session materials; PYMNTS, Aug 14
- Aug 31, 2026
Version 5.0 of the Supplement released
At a public Working Group Webex, the NAIC released version 5.0 of the AI Risk Evaluation Supplement, superseding draft 4.0. The structural changes were large enough that it was issued as a clean version with a separate summary of changes. When the chair opened the floor to interested parties, no comments were offered.
Source: NAIC BDAI (H) WG Aug 31 meeting packet (v5.0 text and summary of changes); attendee notes
- Sep 29, 2026
Written comments on version 5.0 closed
The roughly 30-day written-comment window on version 5.0 closed Sep 29, 2026.
Source: NAIC BDAI (H) WG Aug 31 meeting (timeline as stated)
- Oct 2, 2026
33 comment letters posted
The NAIC posted 33 comment letters on version 5.0. Industry (ACLI, APCIA, NAMIC, AHIP among others) pressed to narrow scope: GLMs out, materiality set by the company, and in some letters removal of Exhibits C and D. A pilot-state regulator (Connecticut DOI) and the NAIC Consumer Representatives pushed the other way, to sharpen it. The stated comment focus was materiality, Direct Consumer Impact, GLMs, and Exhibit A.
Source: NAIC BDAI (H) WG, comments received on v5.0 (posted Oct 2, 2026)
- Oct 8, 2026
Working Group call: pilot update and verbal comments
The Working Group met for a pilot update and verbal comments on version 5.0. Regulators signaled that an examination funnel (is AI used, then Exhibit A, then often Exhibit B, then Exhibits C and D only for a risk-selected set of models) is coming in writing, that submitting existing company documents in lieu of the templates will be clarified as acceptable, and that requests to remove Exhibits C and D were declined.
Source: NAIC BDAI (H) WG call, Oct 8, 2026 (attendee notes)
- Upcoming
- October 2026
Version 6.0 exposed
Version 6.0 is expected in October with a 14-day written-comment window, incorporating the version 5.0 comments.
Source: NAIC BDAI (H) WG Oct 8 call (timeline as stated)
- Nov 2, 2026
Working Group call on the Supplement
A Working Group call on the Supplement is scheduled for Nov 2, 2026, ahead of the Fall National Meeting.
Source: NAIC BDAI (H) WG schedule
- Nov 14–17, 2026
Version 7.0 considered for adoption
Version 7.0 is considered for adoption at the Fall National Meeting, Nov 14–17, 2026, after the 5.0 and 6.0 comment rounds. The Working Group has described the adopted version as a living foundation, not a final text.
Source: NAIC BDAI (H) WG Oct 8 call (timeline as stated)
- 2027
Possible folding into the examiner handbooks
Discussion of folding elements of the Supplement into the Financial Condition Examiners and Market Conduct handbooks is expected in 2027. No decisions have been made.
Source: NAIC BDAI (H) WG Oct 8 call (timeline as stated)
This is the regulatory chronology. For changes to this guide, see the changelog. State-by-state status is in the state tracker.
Self-assessment and orientation only. Nothing here is legal advice, a certification, or a compliance determination. Nolte is not affiliated with or endorsed by the NAIC. Exhibit references are paraphrased from Supplement version 5.0; the wording that counts is the NAIC's. Corrections: j@nolte.io.