Navigating a trio of NHID bulletins

The New Hampshire Insurance Department has released three bulletins to address key regulatory topics that affect insurers and insurance producers in the state.

These updates cover the use of artificial intelligence, how to handle virtual vehicle claims and licensee disclosure requirements. The bulletins indicate a shift in regulatory expectations—with implications for consumer protection standards—technological oversight and professional conduct in the insurance industry.

AI in insurance: Governance and oversight now required

With artificial intelligence becoming deeply embedded in insurance operations—from underwriting to claims decisions—the NHID has set forth detailed expectations in Bulletin INS 24-011-AB for the responsible development and use of AI systems by insurers.

Key takeaways include:

• AI systems must comply with existing insurance laws, including those governing unfair trade practices, rate standards and corporate governance.
• Insurers must implement a formal AI Systems Program with governance, risk management and internal audit controls tailored to the risks posed by their AI use.
• All AI-related activities—including those from third-party vendors—must be transparent, testable and not result in unfairly discriminatory or arbitrary outcomes.

What producers should know

Expect more questions from clients about AI-driven decisions; and understanding your carrier partners’ AI governance will be increasingly important.

Producers may be called upon to assist in explaining or challenging AI-generated outcomes—particularly in claims and pricing.

If you are a member, you can read New Hampshire sets guardrails for AI in insurance: what bulletin INS 24-022-AB means for the industry in the PIA QuickSource Library for more information.

Virtual vehicle claims: In-person inspections remain a right

As insurers embrace digital tools to streamline the claims process, virtual inspections—based on photos or video rather than in-person evaluations—have become increasingly common. However, the NHID’s Bulletin INS 25-031-AB affirms a critical safeguard: the right of the consumer to request a traditional, in-person inspection.

The bulletin clarifies that:

• consumers have the right to request an in-person inspection; and
• insurers must accommodate such requests in a timely manner, regardless of prior virtual submissions.

Failure to comply with a consumer’s request may constitute a violation of RSA 417:4, XV, under the Unfair Claims Settlement Practices statute.

Impact on producers. To adhere to the bulletin, insurance producers will need to:

• inform their clients of their rights to request inspections;
• serve as advocates if inspection delays or denials occur; and
• stay vigilant for patterns of claims mishandling that may indicate compliance risks.

Updated disclosure requirements for licensees

In Bulletin INS 25-034-AB, the NHID provides updated guidance on disclosure obligations for producers and adjusters. Under RSA 402-J:17, 402-D:18, and 402-B:7:

• Administrative actions must be reported within 30 days of final disposition.
• Criminal prosecutions must be reported within 30 days of the first pretrial hearing.

These disclosures also are required at license application and renewal.

Disclosures may be submitted via:

• The NIPR attachment warehouse or
• mailed directly to the NHID Licensing Division.

Failure to comply can result in suspension, revocation or fines.

Questions or concerns can be directed to the NHID’s licensing enforcement team at enforcement@ins.nh.gov.