AI regulation dates for insurance: the current status
Much of the web still reports the EU AI Act's high risk obligations as applying from 2 August 2026. That date moved. This page carries the current dates for insurers, MGAs and delegated authority businesses, checked against the primary sources.
Last checked 6 August 2026. Reviewed quarterly.
European Union
The AI Act, Regulation (EU) 2024/1689, entered into force on 1 August 2024. Article 4 AI literacy obligations for providers and deployers have applied since 2 February 2025.
The high risk obligations were originally scheduled to apply from 2 August 2026. The Digital Omnibus on AI, adopted by the European Parliament on 16 June 2026 and by the Council on 29 June 2026 and published in the Official Journal on 24 July 2026, moved the compliance date for Annex III high risk systems to 2 December 2027.
What counts as high risk in insurance is narrower than most coverage suggests. Annex III point 5(c) covers AI systems intended for risk assessment and pricing in relation to natural persons in life and health insurance. Property and casualty business falls outside that provision and needs its own analysis.
United States
The NAIC Model Bulletin on the Use of Artificial Intelligence Systems by Insurers was adopted on 4 December 2023. By the second quarter of 2026, 25 jurisdictions including the District of Columbia had adopted it. California, Colorado, New York and Texas run their own insurance specific frameworks instead, which puts 29 jurisdictions in scope one way or another.
There is also an AI Systems Evaluation Tool, a structured framework for examiners, being piloted by twelve states through September 2026.
Common questions
From 2 December 2027 for Annex III high risk systems, after the Digital Omnibus moved the original 2 August 2026 date. The change was adopted by the European Parliament on 16 June 2026 and by the Council on 29 June 2026.
The high risk designation for insurance sits in Annex III point 5(c) and covers risk assessment and pricing in relation to natural persons in life and health insurance. Property and casualty falls outside that provision, though other obligations, including AI literacy under Article 4, still apply to deployers.
25 jurisdictions including the District of Columbia as of the second quarter of 2026, with California, Colorado, New York and Texas running their own insurance specific frameworks, which puts 29 jurisdictions in scope one way or another.
Sources
- Regulation (EU) 2024/1689 (the AI Act), Article 4 and Annex III point 5(c).
- Digital Omnibus on AI, adopted by the European Parliament 16 June 2026 and the Council 29 June 2026, published in the Official Journal 24 July 2026.
- National Association of Insurance Commissioners, Model Bulletin: Use of Artificial Intelligence Systems by Insurers, adopted 4 December 2023.
- National Association of Insurance Commissioners, Implementation of NAIC Model Bulletin: state adoption map, accessed August 2026.
- NAIC AI Systems Evaluation Tool, pilot status as at second quarter 2026.