Texas expects human review before action when a regulated entity uses AI to make a consequential decision. Bulletin B-0003-26, issued 12 June 2026, extends its governance expectations to third parties working with regulated entities and states that a person should review and agree with such decisions before action is taken. It also highlights adjuster-licensing requirements for investigating or adjusting losses and supervising claims handling. (tdi.texas.gov)
This is a supervisory bulletin referencing existing legal obligations—not a new nationwide ban on automated estimate preparation. Its separate discussion of adverse determinations by utilisation-review agents should not be presented as a blanket property-claims prohibition. (tdi.texas.gov)
Recommended division of responsibilities:
| Workflow activity | Suggested control |
|---|---|
| Extract measurements or organise photographs | Retain the original evidence and flag uncertainty for correction. |
| Draft a repair scope or recommend deleting an item | Record the recommendation, supporting evidence and reviewing person. |
| Generate a coverage explanation | Require authorised review of policy references and claim-specific reasoning before release. |
| Send a consequential decision or trigger payment-related action | Apply the documented approval and authority controls for that workflow. |
For procurement, the useful question is not simply “Do you use a human in the loop?” Ask which person reviews which decision, what they can see, what they can change and what happens when they disagree. Treat the answer as a demonstrable workflow, not a marketing description.
Sources cited on this page
- tdi.texas.govtdi.texas.gov