Commissioner's Memorandum 2025-13A: The Use of Artificial Intelligence Systems in Insurance (NAIC Model Bulletin adopted by the Hawaii Insurance Division)

Summary

The Hawaii Insurance Division issued Commissioner's Memorandum 2025-13A on December 10, 2025, its version of the NAIC Model Bulletin on insurers' use of AI. It reminds insurers authorized in Hawaii that decisions affecting consumers that are made or supported by AI systems must comply with existing insurance law, including the rules on unfair trade practices and unfair discrimination. It sets the regulator's expectations for a written AI systems program (governance, risk management, internal controls and oversight of third-party AI vendors) and describes the information the regulator may request in an investigation or market conduct examination. This record covers the bulletin only; it is regulatory guidance, not a statute.

Key dates

1. December 10, 2025Takes effect
2. October 16, 2026Checked against sources
3. October 21, 2026Checked against sources

Developments are added when the record is reviewed. Next review: January 15, 2027.

Evidence

Each passage is quoted from its source. The quoted passages are re-checked against the live pages every month.

1. COMMISSIONER’S MEMORANDUM 2025-13A: THE USE OF ARTIFICIAL INTELLIGENCE SYSTEMS IN INSURANCE December 11, 2025 at 2:36 pm

   Supports: Memorandum number and subject; posted December 11, 2025

   Commissioner's Memorandum 2025-13A: The Use of Artificial Intelligence Systems in Insurance Hawaii Department of Commerce and Consumer Affairs, Insurance Division Primary source

2. December 10, 2025 MEMORANDUM 2025-13A To: All Authorized Insurers Offering Policies in the State of Hawaii From: Scott K. Saiki, Insurance Commissioner Subject: The Use of Artificial Intelligence Systems in Insurance

   Supports: Memorandum date (December 10, 2025), issuer, addressees

   Memorandum 2025-13A (signed copy) Troutman Pepper Locke (InsureReinsure blog, hosting the signed memorandum) Reporting or analysis