Bulletin B-0003-26 (2026)Texas's own bulletin

AI governance for Texas insurers

Texas does not adopt the NAIC AI model bulletin. The Texas Department of Insurance runs its own guidance through Commissioner's Bulletin B-0003-26, issued June 12, 2026, on the use of artificial intelligence. The bulletin reminds every regulated entity that any decision affecting a consumer that is made or supported by AI must still comply with existing Texas insurance law, including the statutes on unfair trade practices and prohibited discrimination. It sets out how TDI expects insurers to govern the development, acquisition, and use of AI, and it recognizes the NAIC's 2020 Principles on Artificial Intelligence as appropriate guidance.

BulletinB-0003-26

IssuedJune 12, 2026

EffectiveUpon issuance

BasisExisting Texas law

What Texas requires

Texas does not create a new AIS-Program filing or a standalone AI statute. Instead, TDI frames its expectations around existing obligations: an AI-supported decision is judged by the same standards as any other insurance decision, and the Department expects insurers to govern these tools and to produce the supporting documentation on request.

Compliance with existing law

Treat any decision or action made or supported by AI as subject to the same insurance laws that already apply, including the prohibitions on unfair methods of competition, unfair or deceptive acts, and prohibited discrimination. Outcomes that are inaccurate, arbitrary, capricious, or unfairly discriminatory remain violations regardless of the technology behind them.

Governance & risk management

Stand up governance, risk-management controls, and an internal audit function that cover the development, acquisition, and use of AI. TDI expects monitoring to reach governance frameworks, risk management, data and privacy protections, and internal controls, with procedures and protections producible on request.

Human review & testing for bias

Keep a person in the loop on consequential decisions: TDI expects someone to review and agree with an AI-supported consequential decision before action is taken. Develop and use verification and testing methods to identify errors and bias before deployment and on an ongoing basis.

Third-party accountability

Extend these expectations to any third party that works with a regulated entity. Using a vendor's model or data does not shift responsibility: the regulated entity remains accountable for AI-supported decisions and for the accuracy of the data behind them.

Legal authority

Texas grounds the bulletin in insurance statutes that apply no matter what methodology an insurer uses:

Unfair methods of competition and unfair or deceptive acts or practicesTex. Ins. Code Ch. 541
Prohibited discriminationTex. Ins. Code Ch. 544
Processing and settlement of claimsTex. Ins. Code Ch. 542
Prohibited ratesTex. Ins. Code Ch. 560
Corporate governance annual disclosureTex. Ins. Code Ch. 831

Who it applies to

The bulletin reaches every regulated entity and the parties acting for it:

All insurers authorized to do business in Texas
Property and casualty, life, and health lines
Health maintenance organizations and utilization review agents
Agents, adjusters, and the third parties they rely on

Scope note: B-0003-26 applies to all regulated entities and their agents and representatives across property and casualty, life, and health lines. It sets no threshold by company size and no separate carve-out, so any covered entity using AI to make or support consumer decisions is expected to meet the governance and oversight standards. The bulletin also reaches third parties working with a regulated entity, so vendor use does not move the obligation off the carrier.

Compliance timeline

September 30, 2020TDI issues Commissioner's Bulletin B-0036-20 on insurers' use of third-party data, reminding entities that they remain responsible for the accuracy of data used in rating, underwriting, and claims even when a third party supplies it.
June 12, 2026TDI issues Commissioner's Bulletin B-0003-26 on the use of artificial intelligence, effective upon issuance, setting out the Department's governance and oversight expectations for AI-supported consumer decisions.
OngoingRegulated entities are expected to maintain governance, run error and bias testing, keep human review on consequential decisions, and produce procedures and protections during examinations and market conduct reviews.

Learn the basics

Resources for Texas insurers

Start with these plain-language explainers and field guides.

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 insurer 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 insurers.

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 insurers 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.

Texas insurance AI FAQs

Does Texas follow the NAIC AI model bulletin?

No. Texas issued its own guidance. Commissioner's Bulletin B-0003-26, dated June 12, 2026, sets out how the Texas Department of Insurance expects regulated entities to govern AI. It applies existing Texas insurance law to AI-supported decisions and recognizes the NAIC's 2020 Principles on Artificial Intelligence as appropriate guidance, rather than adopting the NAIC model bulletin structure.

What does Bulletin B-0003-26 actually require?

It reminds regulated entities that any decision affecting a consumer made or supported by AI must comply with existing law, including the prohibitions on unfair trade practices and prohibited discrimination. TDI expects governance, risk-management controls, and internal audit; human review of consequential decisions before action; verification and testing methods to identify errors and bias; and the ability to produce procedures and protections on request.

Which entities does the bulletin cover?

It applies to all regulated entities and their agents and representatives, across property and casualty, life, and health lines. It sets no threshold by company size, so any covered entity using AI to make or support consumer decisions is in scope, and the expectations also extend to third parties working with a regulated entity.

What about third-party models and data?

Responsibility stays with the regulated entity. B-0003-26 extends its expectations to any third party that works with a regulated entity, and the earlier Bulletin B-0036-20 already made clear that an insurer remains responsible for the accuracy of data used in rating, underwriting, and claims even when a third party provides it.

When does the bulletin take effect and what are the deadlines?

TDI issued B-0003-26 on June 12, 2026 and it is effective upon issuance, with no separate phase-in period or filing deadline. Because the obligations rest on laws already in force, TDI expects entities to govern and test their AI now and to be able to produce the supporting documentation during examinations and market conduct reviews.

Sources

Get audit-ready for Texas's AI bulletin

Swept AI inventories your models and the data behind them, runs the error and bias testing Texas expects, and produces the governance documentation TDI can request during an examination.