The regulatory environment for agentic AI in insurance is not waiting for the industry to catch up. Through 2024, 2025, and the first half of 2026, insurance regulators on both sides of the Canada-United States border (and across the Atlantic) have been issuing guidance, opening consultations, and finalizing rules at a rate that surprises most carrier risk officers when they map it out.
This piece is a map. Not legal advice. A practical guide for insurance leaders, second-line risk and compliance functions, and boards trying to understand the agentic AI regulatory landscape they are operating inside as of mid-2026.
The regulators that matter and what they are doing
National Association of Insurance Commissioners (NAIC). The NAIC's model bulletin on AI was issued in late 2023 and has been adopted, in some form, by an expanding set of state insurance regulators through 2025 and into 2026. The bulletin provides principles rather than prescriptive frameworks, with a focus on governance, testing, validation, transparency, fairness, and cybersecurity. The model bulletin is not a rule by itself. It is the template state regulators are using to write rules. Carriers operating across many states should treat the bulletin as a near-universal baseline and track state-by-state variation where it matters.
Colorado Division of Insurance. Colorado issued one of the more concrete state-level AI frameworks in 2024, focused specifically on algorithmic fairness in life insurance underwriting. The regulation requires governance over external consumer data and information sources, including testing for unfair discrimination. Colorado is the most-cited example of a state regulator moving from principles to prescriptive requirements, and it is likely to influence other states' rule-making through 2026 and 2027.
New York Department of Financial Services. New York has issued guidance on AI and external consumer data in insurance underwriting, with explicit expectations on governance, risk management, and consumer protection. New York's posture tends to be a leading indicator for what other large-state regulators will adopt.
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