Reference · verified against the NAIC implementation map, status April 1, 2026
The NAIC's model bulletin on insurers' use of artificial intelligence systems is adopted state by state, each under its own instrument number. The table lists the adoptions this lab has verified against the NAIC implementation map and works with today. More than twenty states have adopted the model in total; if your state adopted it and isn't listed here, the crosswalk still applies, and we'll confirm your instrument's numbering if you write us.
| State | Instrument | Notes |
|---|---|---|
| Iowa | Iowa Insurance Division Bulletin 24-04 (Nov. 7, 2024) | NAIC exam-pilot state, Mar–Sep 2026. |
| Wisconsin | OCI bulletin on AI systems (Mar. 18, 2025) | NAIC exam-pilot state. |
| Virginia | Administrative Letter 2024-01 (Jul. 2024) | NAIC exam-pilot state. |
| Connecticut | Bulletin MC-25 (Feb. 26, 2024) | NAIC exam-pilot state. Connecticut domestics also file an annual AI certification, due on or before September 1. Details. |
| Pennsylvania | Insurance Notice 2024-04, 54 Pa.B. 1910 (Apr. 6, 2024) | NAIC exam-pilot state. |
| Oklahoma | OID Bulletin No. 2024-11 (Nov. 14, 2024) | Not a pilot state. Oklahoma-specific crosswalk: OID 2024-11. |
| Rhode Island | Insurance Bulletin 2024-03 | NAIC exam-pilot state. |
| Vermont | Insurance Bulletin No. 229 | NAIC exam-pilot state. |
| Maryland | Bulletin 24-11 | NAIC exam-pilot state. |
A note on the exam pilot, because the two lists get mixed up. The twelve pilot states are CA, CO, CT, FL, IA, LA, MD, PA, RI, VT, VA, WI. Piloting the exam checklist isn't the same thing as adopting the model bulletin: Florida and Louisiana pilot without having adopted it, and California and Colorado operate their own distinct AI regimes (CA Bulletin 2022-5; CO 3 CCR 702-10), which our crosswalk doesn't map.
What this page is for: insurers in adopting states get asked to document testing and validation of the AI systems they use. Spectralgraph is an independent AI-testing laboratory; the provision-by-provision crosswalk maps our LLM Validation Report to the model bulletin's text, so a compliance file can point at the exact provision a measurement answers. The crosswalk is the same for every adopting state; only the instrument numbering changes.