AI Legislative Guide |
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USA, Iowa |
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(United States)
Firm
Faegre Drinker Biddle & Reath LLP
Contributors
Eli Burriss |
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| Has specific legislation, final regulations or other formal regulatory guidance addressing the use of AI in your jurisdiction been implemented (vs reliance on existing legislation around IP, cyber, data privacy, etc.)? | No. Iowa has not enacted any legislation or final regulation addressing the use of AI in Iowa. The Iowa Department of Insurance issued Bulletin 24-04, which provides that insurers who have been issued a certificate of authority to conduct business in Iowa are advised that the use of AI systems must comply with existing Iowa law. The bulletin requires insurers to adopt and implement a written AI policy. The Iowa Department of Management adopted a Gen AI Policy, but it only applies to state agencies. |
| Please provide a short summary of the legislation/regulations/guidance and explain how legislators aim to strike the balance between innovation and regulation. | Bulletin 24-04 states that insurers who have been issued a certificate of authority to conduct business in Iowa are “reminded” that the insurers using AI systems must comply with Iowa law and ensure, at a minimum, that decisions made by insurers must are not inaccurate, arbitrary, capricious, or unfairly discriminatory, regardless of the tools and methods used to make such decisions. Accordingly, Bulletin 24-04 requires insurers to implement and maintain an AIS Program that meets 8 objectives stated in the Bulletin. Among those objections are that the AIS Program should be designed to mitigate the risk that use of an AI system will result in an outcome adverse to consumers, and that the AIS program should include processes and procedures providing notice to impacted consumers that AI Systems are in use and provide access to appropriate levels of information based on the phase of the insurance life cycle in which the AI Systems are being used. Bulletin 24-04 further provides that the Iowa Division of Insurance has the authority to regulate the use of AI systems by insurers in Iowa and cautions that insurers subject to the jurisdiction of the Iowa DoI can expect to be asked about the development, deployment, and use of AI systems, including the use of AI systems developed by third-parties that the insurers may be using. Bulletin 24-04 contains an extensive list of information that the DoI may request from an insurer. |
| Which agency regulates the use of AI in your jurisdiction? | Not applicable. |
AI Legislative Guide
USA, Iowa
(United States) Firm Faegre Drinker Biddle & Reath LLPContributors Eli Burriss
Updated 03 Jul 2025No.
Iowa has not enacted any legislation or final regulation addressing the use of AI in Iowa.
The Iowa Department of Insurance issued Bulletin 24-04, which provides that insurers who have been issued a certificate of authority to conduct business in Iowa are advised that the use of AI systems must comply with existing Iowa law. The bulletin requires insurers to adopt and implement a written AI policy.
The Iowa Department of Management adopted a Gen AI Policy, but it only applies to state agencies.
Bulletin 24-04 states that insurers who have been issued a certificate of authority to conduct business in Iowa are “reminded” that the insurers using AI systems must comply with Iowa law and ensure, at a minimum, that decisions made by insurers must are not inaccurate, arbitrary, capricious, or unfairly discriminatory, regardless of the tools and methods used to make such decisions.
Accordingly, Bulletin 24-04 requires insurers to implement and maintain an AIS Program that meets 8 objectives stated in the Bulletin. Among those objections are that the AIS Program should be designed to mitigate the risk that use of an AI system will result in an outcome adverse to consumers, and that the AIS program should include processes and procedures providing notice to impacted consumers that AI Systems are in use and provide access to appropriate levels of information based on the phase of the insurance life cycle in which the AI Systems are being used.
Bulletin 24-04 further provides that the Iowa Division of Insurance has the authority to regulate the use of AI systems by insurers in Iowa and cautions that insurers subject to the jurisdiction of the Iowa DoI can expect to be asked about the development, deployment, and use of AI systems, including the use of AI systems developed by third-parties that the insurers may be using. Bulletin 24-04 contains an extensive list of information that the DoI may request from an insurer.
Not applicable.