New York · Senate Bill · 2025–2026 Regular Session
SB9393
New York Senate Bill 9393 — An Act to amend the insurance law, in relation to requiring insurance carriers to provide access to underwriting models or granular claim data to the department of financial services

Status ● Introduced Effective N/A Passage Likelihood L

WHAT THIS BILL REGULATES · 1 REQUIREMENT TYPE

How Is This Bill Enforced

Enforcement Authority
Enforcement by the New York Department of Financial Services (DFS) through the Superintendent. No private right of action. Non-compliance constitutes a violation subject to penalties under Insurance Law § 109, including fines, suspension, or revocation of license.
Private Right of Action
No private right of action. Enforcement is exclusive to the designated authority.
Penalties
Penalties under Insurance Law § 109, which may include fines, suspension, or revocation of license. No private damages remedy. Specific fine amounts are governed by the cross-referenced § 109 rather than this section.

What This Bill Requires

Verbatim statutory text on the left; plain-language analysis and a per-section checklist on the right. Numbered markers cross-link to the matching checklist row.

Statutory Text
Analysis & Obligations
Ins. Law § 338(a)
Definitions

(a)(1)–(3) Definitions. For purposes of this section: (1) "Underwriting modelUnderwriting model"Underwriting model" means any algorithm, formula, or structured methodology used by an insurance carrier to assess risk, determine premiums, or evaluate eligibility for coverage.Ins. Law § 338(a)(1)" means any algorithm, formula, or structured methodology used by an insurance carrierInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) to assess risk, determine premiums, or evaluate eligibility for coverage. (2) "Granular claim dataGranular claim data"Granular claim data" means detailed, record-level information regarding claims, including but not limited to claim type, amount, date, geographic location, and resolution status.Ins. Law § 338(a)(2)" means detailed, record-level information regarding claims, including but not limited to claim type, amount, date, geographic location, and resolution status. (3) "Mutually agreed department staffMutually agreed department staff"Mutually agreed department staff" means employees or agents of the department designated by the superintendent and agreed upon with the insurance carrier for purposes of review.Ins. Law § 338(a)(3)" means employees or agents of the department designated by the superintendent and agreed upon with the insurance carrierInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) for purposes of review.

Subsection (a) establishes three defined terms that frame the scope of the regulatory access mandate. Underwriting model is defined broadly to include any algorithm, formula, or structured methodology used to assess risk, determine premiums, or evaluate coverage eligibility — a definition wide enough to capture traditional actuarial formulas as well as machine-learning and AI-based underwriting tools. Granular claim data covers detailed record-level claims information. Mutually agreed department staff limits the personnel who may access carrier information to those designated by the Superintendent and agreed upon with the carrier, providing a procedural safeguard.

Ins. Law § 338(b)
Access to underwriting models
Deployer

(b) 1 Access to underwriting modelsUnderwriting model"Underwriting model" means any algorithm, formula, or structured methodology used by an insurance carrier to assess risk, determine premiums, or evaluate eligibility for coverage.Ins. Law § 338(a)(1). Every insurance carrierInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) authorized to do business in this state shall provide access to its underwriting modelsUnderwriting model"Underwriting model" means any algorithm, formula, or structured methodology used by an insurance carrier to assess risk, determine premiums, or evaluate eligibility for coverage.Ins. Law § 338(a)(1) to mutually agreed department staffMutually agreed department staff"Mutually agreed department staff" means employees or agents of the department designated by the superintendent and agreed upon with the insurance carrier for purposes of review.Ins. Law § 338(a)(3), upon request of the superintendent.

Subsection (b) imposes the bill's primary regulatory access obligation: every authorized insurance carrier must provide access to its underwriting models to mutually agreed DFS staff upon the Superintendent's request. This is the core mechanism by which DFS can examine algorithmic or formulaic underwriting practices for fairness, accuracy, and compliance with insurance law. The access is request-driven — carriers need not proactively submit models, but must produce them when asked.

Compliance actions 1 item
1
Insurance carriersInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) authorized to do business in New York must provide DFS access to their underwriting modelsUnderwriting model"Underwriting model" means any algorithm, formula, or structured methodology used by an insurance carrier to assess risk, determine premiums, or evaluate eligibility for coverage.Ins. Law § 338(a)(1) — including any algorithm, formula, or structured methodology used to assess risk, determine premiums, or evaluate coverage eligibility — upon request of the Superintendent, through mutually agreed department staffMutually agreed department staff"Mutually agreed department staff" means employees or agents of the department designated by the superintendent and agreed upon with the insurance carrier for purposes of review.Ins. Law § 338(a)(3).
R-02.2
Ins. Law § 338(c)
Access to granular claim data
Deployer

(c) 2 Access to granular claim dataGranular claim data"Granular claim data" means detailed, record-level information regarding claims, including but not limited to claim type, amount, date, geographic location, and resolution status.Ins. Law § 338(a)(2). In the event that underwriting modelsUnderwriting model"Underwriting model" means any algorithm, formula, or structured methodology used by an insurance carrier to assess risk, determine premiums, or evaluate eligibility for coverage.Ins. Law § 338(a)(1) are not available, an insurance carrierInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) shall provide access to granular claim dataGranular claim data"Granular claim data" means detailed, record-level information regarding claims, including but not limited to claim type, amount, date, geographic location, and resolution status.Ins. Law § 338(a)(2) to mutually agreed department staffMutually agreed department staff"Mutually agreed department staff" means employees or agents of the department designated by the superintendent and agreed upon with the insurance carrier for purposes of review.Ins. Law § 338(a)(3), sufficient to allow the department to evaluate underwriting practices and risk assessment methodologies.

Subsection (c) creates a fallback obligation: when underwriting models are not available — whether because they are proprietary third-party systems, not reducible to a reviewable form, or otherwise inaccessible — the carrier must instead provide granular claim data sufficient for DFS to evaluate underwriting practices and risk assessment methodologies. This ensures DFS retains regulatory visibility even when model access is impracticable.

Compliance actions 1 item
2
Insurance carriersInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) must, when underwriting modelsUnderwriting model"Underwriting model" means any algorithm, formula, or structured methodology used by an insurance carrier to assess risk, determine premiums, or evaluate eligibility for coverage.Ins. Law § 338(a)(1) are not available, provide DFS access to granular claim dataGranular claim data"Granular claim data" means detailed, record-level information regarding claims, including but not limited to claim type, amount, date, geographic location, and resolution status.Ins. Law § 338(a)(2) — including claim type, amount, date, geographic location, and resolution status — sufficient to allow the department to evaluate the carrier's underwriting practices and risk assessment methodologies.
R-02.2
Ins. Law § 338(d)
Confidentiality protections

(d) Confidentiality. Information provided under this section shall be subject to confidentiality protections consistent with applicable state and federal law. Department staff shall maintain such information solely for regulatory purposes.

Subsection (d) provides that all information disclosed under this section is subject to confidentiality protections consistent with applicable state and federal law, and restricts DFS staff to using the information solely for regulatory purposes. This provision does not create an affirmative compliance obligation on the carrier — it constrains DFS's use of the disclosed information.

Ins. Law § 338(e)
Compliance and penalties

(e) Compliance. Failure to comply with this section shall constitute a violation and may subject the insurance carrierInsurance carrierEvery insurance carrier authorized to do business in this state.Ins. Law § 338(b) to penalties under section one hundred nine of this chapter, including fines, suspension, or revocation of license.

Subsection (e) establishes the enforcement mechanism: failure to comply with the section's access requirements constitutes a violation that may subject the carrier to penalties under Insurance Law § 109, which authorizes fines, license suspension, or license revocation. This is the sole enforcement mechanism — no private right of action is created.

§ 2
Effective date

This act shall take effect on the ninetieth day after it shall have become a law.

The act takes effect on the ninetieth day after it becomes law. Because the bill has not been enacted, no specific effective date can be computed.

Passage Likelihood

Low
Status Introduced
Chamber No passage
Committee No action
Majority party Yes
Bipartisan No
Prior session None

Legislative History

2026-03-09 REFERRED TO INSURANCE

Entry Last Reviewed

2026-05-20
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