AI governance for Maryland insurers
The Maryland Insurance Administration issued Bulletin No. 24-11 on April 22, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers. It reminds carriers that any decision or action impacting consumers, made or supported by AI, must comply with Maryland insurance law, including the unfair trade practices and unfair claim settlement standards in Title 27. The Administration expects every carrier to develop and maintain a written AIS Program sized to the risk of adverse consumer outcomes, 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.
What Maryland expects from your AIS Program
Maryland 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 insurer 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 Maryland Insurance Administration grounds the bulletin in laws it already enforces:
- Unfair Trade Practices and Other Prohibited PracticesMd. Code Ann., Insurance, Title 27
- Insurance Rating Law (Property and Casualty)Md. Code Ann., Insurance, Title 11, Subtitles 2 and 3
- Corporate Governance Annual Disclosure ActMd. Code Ann., Insurance, Title 4, Subtitle 5
Who it applies to
The bulletin reaches every entity holding a Maryland certificate of authority, including:
- All insurers holding a Maryland certificate of authority
- Nonprofit health service plans
- Health maintenance organizations
- Dental plan organizations
State-specific changes: Maryland follows the NAIC model closely, anchoring it to its own statutes: Title 27 for unfair trade and claims practices, Title 11 for property and casualty rate adequacy, and Title 4, Subtitle 5 for corporate governance disclosure. An insurer building to the national framework is building to Maryland's expectations.
Resources for Maryland insurers
Start with these plain-language explainers and field guides.
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.
GuideWhat is an AIS Program?
An AI Systems Program (AIS Program) is the written program the NAIC Model Bulletin expects every insurer to maintain. Here are its four pillars and what each one requires.
GuideWhat 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.
GuideAI 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 insurers.
ArticleInsurance 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 insurers to operationalize AI governance, not just document it.
ArticleThe 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.
Maryland AI governance FAQs
What is Maryland Bulletin No. 24-11?
Which companies have to comply in Maryland?
Does the bulletin reference the NAIC AI Principles?
How will Maryland enforce it?
How does a Maryland carrier get ready?
Sources
- Maryland Insurance Administration: Bulletin No. 24-11 (Apr 22, 2024)
- NAIC Model Bulletin on the Use of AI Systems by Insurers (Dec 4, 2023)
- Md. Code Ann., Insurance, Title 27 (Unfair Trade Practices and Other Prohibited Practices)
- Md. Code Ann., Insurance, Title 11 (Insurance Rating Law)
- Md. Code Ann., Insurance, Title 4, Subtitle 5 (Corporate Governance Annual Disclosure Act)
Get audit-ready for Maryland Bulletin 24-11
Swept AI supervises your models and produces the AIS Program evidence Maryland examiners can request.