What NAIC and State Insurance Regulators Currently Say
Three insurance-specific regulator documents govern AI use in underwriting, pricing, and claims today,
plus one legislators’ model act still in draft — and not one of them uses “Super
Intelligence” or “SI”:
| Regulator | Current document | Date | Terminology used |
| NAIC |
Model Bulletin on the Use of Artificial Intelligence Systems by Insurers |
Adopted Dec 4, 2023 |
“AI systems” throughout |
| New York DFS |
Insurance Circular Letter No. 7 (AI underwriting & pricing) |
Adopted Jul 11, 2024 |
“Artificial Intelligence Systems” (AIS) |
| Colorado DOI |
SB21-169 & Reg. 10-1-1 (governance & risk management) |
Reg. effective Nov 14, 2023 |
External consumer data, algorithms & predictive models |
| NCOIL |
Draft Model Act Regarding Insurers’ Use of AI (not yet adopted) |
Draft dated Jun 17, 2025 |
“Artificial Intelligence” |
NAIC. The Model Bulletin on the Use of Artificial Intelligence Systems by Insurers,
adopted by NAIC’s Executive Committee and Plenary on December 4,
2023 (Source: NAIC, Model Bulletin on the Use of Artificial Intelligence Systems by Insurers),
expects insurers to “develop, implement, and maintain a written program for responsible use of AI
systems,” overseen by a “clear governance accountability
structure” (Source: Quarles & Brady, States Adopt NAIC Model Bulletin on Insurers’ Use of AI).
As of July 2026, 25 states had formally adopted the Bulletin with 8 more in
progress (Source: Openlayer, NAIC AI Model Bulletin: What Insurers Must Prepare for in July 2026)
— a count that kept rising through the same months the federal rename appeared, up from 24 states
as of March 2025 (Source: Quarles & Brady, Nearly Half of States Have Now Adopted NAIC Model Bulletin).
No “Super Intelligence” or “SI” language appears anywhere in the Bulletin or on
NAIC’s AI topic page.
New York. NY DFS’s Insurance Circular Letter No. 7 governs AI systems and external
consumer data used in underwriting and pricing specifically — it does not reach claims adjusting or
marketing. Adopted July 11, 2024 with only minor changes from its January 2024
proposal (Source: Willkie Farr & Gallagher, NYDFS Adopts Circular Letter on the Use of AI in Insurance),
it is organized around three principles — Fairness, Governance and Risk Management, and
Transparency — and frames its fairness expectation around not using an AI system or external data
source for underwriting or pricing unless an insurer can establish the system does not rely on any
legally protected classification under New York Insurance Law Article
26 (Source: Alston & Bird, NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing).
No “Super Intelligence” language appears in the circular letter.
Colorado. SB21-169, signed July 6, 2021, and its implementing Regulation 10-1-1 (in
effect for life insurers since November 14, 2023, with auto and health insurers’ frameworks due by
July 1, 2026) require insurers to inventory the external consumer data and algorithms they use across
marketing, underwriting, pricing, and claims
management (Source: Credo AI, Colorado SB21-169: 8 Things You Need to Know).
This insurance-specific rule is legally distinct from Colorado’s general AI law (SB 24-205, repealed
and replaced by SB 26-189, effective January 1,
2027 (Source: Eckert Seamans, Colorado Repeals and Replaces Its Landmark AI Statute));
the two should not be conflated. As of October 2026, no Colorado DOI publication uses “Super
Intelligence” or “SI” terminology.
No insurance regulator at any level — NAIC, New York, Colorado, or any of the other 25
adopting states — has adopted “Super Intelligence” or “SI” terminology as
of October 11, 2026. NCOIL’s separate, not-yet-adopted draft model act on claims-handling AI
oversight is further evidence that current insurance-regulatory activity is ongoing and still written without
“Super Intelligence” or “SI” (Source: NCOIL, Model Act Regarding Insurers’ Use of Artificial Intelligence (draft)).
For the broader use cases these rules govern, see Iternal’s
banking, financial services &
insurance use cases, which this terminology shift does not change.