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Company Bulletin 2024-08Adopted

AI governance for Illinois carriers

The Illinois Department of Insurance issued Company Bulletin 2024-08 on March 13, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It reminds every carrier holding a certificate of authority in Illinois that decisions affecting consumers must comply with applicable insurance law, including the unfair trade practices and unfair discrimination statutes, regardless of whether an AI system produced them. The Department expects each carrier to develop, implement, and maintain a written AIS Program sized to the degree of potential harm a model could cause, and it recognizes the NAIC's 2020 Principles on Artificial Intelligence as an appropriate source of guidance. The bulletin reaches the full insurance life cycle, from product development and underwriting through claims and fraud detection.

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BulletinCompany Bulletin 2024-08
IssuedMarch 13, 2024
EffectiveUpon issuance
BasisNAIC model bulletin

What Illinois expects from your AIS Program

Illinois adopted the NAIC model verbatim, so the program expectations match the national framework.

Governance

A written program with clear ownership. Senior management is accountable to the board, and a cross-functional body oversees AI across its whole life cycle.

Risk Management & Internal Controls

Controls at every stage of the model life cycle, from data sourcing through retirement, sized to the potential harm to consumers.

Third-Party AI Systems & Data

The carrier stays responsible for AI it did not build. Vendor relationships need diligence, contract rights, and the ability to produce evidence.

Documentation & Audit-Readiness

Section 4 spells out what an examiner can ask for. Treating that list as a standing requirement is what keeps a program defensible.

Legal authority

The Illinois Department of Insurance grounds the bulletin in laws it already enforces:

  • Unfair Methods of Competition and Unfair and Deceptive Acts and Practices215 ILCS 5/421 et seq.
  • Property and Casualty Rating (unfair rate discrimination)215 ILCS 5/424
  • Corporate Governance Annual Disclosure215 ILCS 5/130.1-130.7

Who it applies to

The bulletin reaches every entity holding a Illinois certificate of authority, including:

  • Property and casualty carriers
  • Life and annuity carriers
  • Health carriers and HMOs
  • All other entities holding an Illinois certificate of authority

State-specific changes: Illinois adopted the NAIC model with no notable changes, so the substance tracks the national framework section by section. A carrier building to the NAIC model is building to Illinois's expectations.

Illinois also passed a frontier AI law: SB 315

On July 9, 2026, Governor JB Pritzker signed SB 315, the Artificial Intelligence Safety Measures Act (Public Act 104-0538), making Illinois the third state after California and New York to regulate frontier AI. The law governs large frontier developers, meaning the companies that train the biggest models and report more than $500 million in annual revenue, and it is enforced by the Attorney General. No carrier meets that definition, and it does not change Company Bulletin 2024-08.

The reason it belongs on a carrier's radar is the audit. SB 315 makes an independent, annual, third-party AI audit a statutory requirement for the first time in the country, alongside a published safety framework and 72-hour incident reporting. That documented-evidence standard is the same one NAIC market conduct examinations, the AI Systems Evaluation Tool, and reinsurer diligence are already moving toward for carriers.

Read the full breakdown
LawSB 315 (Public Act 104-0538)
SignedJuly 9, 2026
BindsLarge frontier developers (>$500M revenue)
Developer obligationsBegin January 1, 2028
Learn the basics

Resources for Illinois carriers

Start with these plain-language explainers and field guides.

Article

Illinois Wrote Independent AI Audits Into Law. Carriers Should Read the Fine Print.

Illinois SB 315, the Artificial Intelligence Safety Measures Act, makes first-in-nation annual independent AI audits law for frontier developers. It doesn't regulate carriers. The audit standard it sets is the part carriers should read.

Guide

What is the NAIC Model Bulletin on AI?

The NAIC Model Bulletin on the Use of AI Systems by Insurers is the template most states use to set AI governance expectations. Here is what it says and why it matters.

Guide

What is an AIS Program?

An AI Systems Program (AIS Program) is the written program the NAIC Model Bulletin expects every carrier to maintain. Here are its four pillars and what each one requires.

Guide

What are the NAIC AI Principles?

The NAIC AI Principles, adopted in 2020, are the foundation beneath every state AI bulletin. The five principles spell FACTS: Fair, Accountable, Compliant, Transparent, and Secure.

Guide

AI in Insurance: Key Regulatory Definitions

The NAIC Model Bulletin defines the terms that carry legal weight, from AI System to Adverse Consumer Outcome to Model Drift. Here is what each one means for carriers.

Article

Insurance Regulators Are Forcing AI Governance. Most Carriers Aren't Ready.

State insurance regulators and bar associations are sounding the alarm on AI in insurance. Legal and regulatory pressure is forcing carriers to operationalize AI governance, not just document it.

Article

The NAIC Bulletin Is the Floor Your Reinsurer Will Hold You To

Twenty-four jurisdictions have adopted the NAIC Model Bulletin on AI. Most carrier compliance teams are working to the regulatory text. Their reinsurers will use the same document as an evidentiary baseline at the next placement, and the cedent that meets the floor and stops there is preparing for the wrong audience.

Illinois AI governance FAQs

What is Illinois Company Bulletin 2024-08?
It is the bulletin the Illinois Department of Insurance issued on March 13, 2024 adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It tells carriers that existing Illinois insurance laws apply to any decision an AI system touches and expects each carrier to maintain a written AIS Program.
Which companies have to comply in Illinois?
Any carrier holding an Illinois certificate of authority, across property and casualty, life, and health lines. The bulletin reaches AI systems used in regulated insurance practices whether the carrier built them or acquired them from a third party.
Does the bulletin reference the NAIC AI Principles?
Yes. Company Bulletin 2024-08 recognizes the NAIC's 2020 Principles on Artificial Intelligence (fairness and ethics, accountability, compliance, transparency, and a safe, secure, fair, and robust system) as an appropriate source of guidance for building and using AI systems.
How will Illinois enforce it?
Through existing authority. The bulletin ties AI use to the unfair methods of competition and deceptive practices statute (215 ILCS 5/421 et seq.), the improper claims practices statute (215 ILCS 5/154.5), the rating provisions including 215 ILCS 5/424, and the Corporate Governance Annual Disclosure statutes (215 ILCS 5/130.1-130.7). The Department can request AIS Program documentation during investigations and market conduct actions.
How does an Illinois carrier get ready?
Stand up a written AIS Program covering governance, risk management and internal controls, and third-party oversight, then keep model inventories, validation and drift records, and a clear data-to-decision trail examination-ready.
Does Illinois SB 315, the Artificial Intelligence Safety Measures Act, apply to carriers?
Not in practice. SB 315 (Public Act 104-0538), signed July 9, 2026, regulates large frontier developers, meaning companies that train the largest AI models and report more than $500 million in annual revenue, and it is enforced by the Attorney General rather than the Department of Insurance. No carrier meets that definition, and the law does not change Company Bulletin 2024-08, which remains the rulebook for carriers' use of AI in Illinois. What makes SB 315 relevant to carriers is its standard: it makes an independent, annual, third-party AI audit a legal requirement for the first time in the country, and that documented-evidence expectation is the direction NAIC examinations and reinsurer diligence are already taking.
Sources
  1. Illinois DOI: Company Bulletin 2024-08 (March 13, 2024)
  2. NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
  3. NAIC Big Data and AI (H) Working Group: model bulletin implementation map
  4. 215 ILCS 5/421 (Illinois Insurance Code, Article XXVI: Unfair Methods of Competition and Unfair and Deceptive Acts and Practices)
  5. 215 ILCS 5/424 (Illinois Insurance Code, Article XXVI: unfair methods of competition and unfair discrimination defined)
  6. 215 ILCS 5/130.1 to 130.7 (Illinois Insurance Code, Corporate Governance Annual Disclosure Law)
  7. Illinois SB 315, Artificial Intelligence Safety Measures Act (enrolled full text, Public Act 104-0538)
  8. Insurance Journal / Capitol News Illinois: Illinois Governor Signs AI Regulation Bill (July 9, 2026)

Get audit-ready for Illinois Company Bulletin 2024-08

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