This document is a procurement framework, not a state-by-state legal opinion.
The NAIC model bulletin was adopted on 4 December 2023. It is not itself one uniformly binding federal AI rule. The NAIC’s state-action map reviewed for this research is dated 8 October 2026 and includes a warning that the map does not determine whether every state action contains all elements of the model. Use it to locate the relevant state instruments, not as a substitute for reading them. (content.naic.org)
The model bulletin’s third-party provisions contemplate diligence, audit rights or reports, and cooperation with regulatory inquiries. The buyer should establish which applicable state expectations and contractual rights support access to the evidence needed for its own use case. (content.naic.org)
Texas maintains specific property-and-casualty adjuster licensing routes and requirements. Do not infer from the label “estimate writer” that a person’s actual activities are exempt; ask counsel to assess tasks, location, authority and any applicable exceptions. (tdi.texas.gov)
For New York DFS-regulated covered entities, the 21 October 2025 third-party guidance clarifies existing cybersecurity obligations and recommends lifecycle controls; it expressly states that it does not create new requirements. Do not present every suggested contract clause as mandatory nationwide. (dfs.ny.gov)
Finally, contractual production clocks should not obscure applicable claims-handling deadlines. Assign an owner to maintain the relevant deadline and escalation matrix for the deployment.
Sources cited on this page
- content.naic.orgcontent.naic.org
- content.naic.orgcontent.naic.org
- tdi.texas.govtdi.texas.gov
- dfs.ny.govdfs.ny.gov