AI governance for New Hampshire insurers
The New Hampshire Insurance Department issued Bulletin Docket #INS 24-011-AB on February 20, 2024, adopting the NAIC Model Bulletin on the Use of AI Systems by Insurers and putting the state among the earliest to act. The bulletin reminds insurers that any decision an AI system makes or supports must still comply with New Hampshire insurance law, and it expects each insurer to maintain a written AIS Program sized to the harm a model could cause a consumer. New Hampshire follows the national structure closely but sharpens two points: it strongly encourages verification and testing methods to catch errors and limit unfair discrimination, and it frames the data practice as unfair bias analysis and minimization. The Department grounds enforcement and examination authority in laws it already uses, including RSA 400-A:16 and RSA 400-A:37.
What New Hampshire expects from your AIS Program
New Hampshire adopted the NAIC model with some changes. The four pillars below are the shared foundation.
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
New Hampshire Insurance Department grounds the bulletin in laws it already enforces:
- Unfair Trade Practices ActN.H. RSA 417
- Property and Casualty Rate Standards LawN.H. RSA 412:15
- Corporate Governance Annual Disclosure ActN.H. RSA 401-D
Who it applies to
The bulletin reaches every entity holding a New Hampshire certificate of authority, including:
- Property and casualty insurers
- Life and annuity insurers
- Health insurers and HMOs
- All other insurers licensed to do business in New Hampshire
State-specific changes: New Hampshire tracks the NAIC model but tightens the language in two places: it strongly encourages verification and testing of predictive models, and it describes the data control as unfair bias analysis and minimization. The core AIS Program expectations match the national framework.
Resources for New Hampshire 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.
New Hampshire AI governance FAQs
What is New Hampshire Bulletin Docket #INS 24-011-AB?
Which companies have to comply in New Hampshire?
Did New Hampshire change the NAIC model?
How will New Hampshire enforce it?
How does a New Hampshire insurer get ready?
Sources
- New Hampshire Insurance Department: Bulletin Docket #INS 24-011-AB (February 20, 2024)
- NAIC implementation of the AI Model Bulletin (April 2024 tracker)
- NAIC Model Bulletin on the Use of AI Systems by Insurers (December 4, 2023)
- N.H. RSA 417 (Unfair Insurance Trade Practices)
- N.H. RSA 412:15 (Property and Casualty Rate Standards)
- N.H. RSA 401-D (Corporate Governance Annual Disclosure Act)
Get audit-ready for New Hampshire's AI bulletin
Swept AI supervises your models and produces the AIS Program evidence New Hampshire examiners can request.