USA: agent licensing, the NAIC AI bulletin and a wave of agency consolidation

In the US, insurance intermediaries are called producers – a term covering both agents and brokers. They are licensed not by federal authorities but by the regulators of each state. According to the National Association of Insurance Commissioners (NAIC), more than 2 million individuals and more than 236,000 legal entities are licensed in the country.

How licensing works

The Gramm–Leach–Bliley Act of 1999 required states to standardize the licensing of non-residents or to recognize each other's licences. The response was the NAIC Producer Licensing Model Act and the NIPR (National Insurance Producer Registry), established under the NAIC in 1996. NIPR maintains a database of producers across the 50 states, the District of Columbia and the territories, and through an electronic gateway accepts applications for licences, renewals, appointments of agents by insurers and their termination. In 2011, an NAIC working group recommended that 40 jurisdictions be recognized as meeting the reciprocity criteria. In 2015, the NARAB II Act on a voluntary "one-stop shop" for non-residents was signed into law; however, as the NAIC acknowledges, full reciprocity has never been achieved: several large states have not become fully reciprocal. In 2026, NAIC working groups continue to revise the chapters of the State Licensing Handbook and the uniform licensing standards.

AI: the NAIC model bulletin

On 4 December 2023, the NAIC adopted a model bulletin on the use of AI systems by insurers. The document reminds insurers that decisions made or supported by AI must comply with all insurance laws, expects insurers to have a written AI governance program and describes what information the regulator may request during an examination. According to the NAIC, as of 31 August 2026 the bulletin had been adopted by 26 jurisdictions, from Alaska (February 2024) to Mississippi (July 2026). Four more states (California, Colorado, New York and Texas) operate under their own acts. Since 2026, 12 states have been piloting a tool for evaluating AI systems in insurer examinations; its adoption is expected at the NAIC Fall National Meeting in 2026.

At the federal level, the situation is tense. In December 2025, a presidential executive order was signed targeting state-level AI regulation. On 16 December 2025, the NAIC expressed deep concern and urged the administration, at a minimum, to confirm the states' right to regulate AI in insurance.

Annuities: the best interest standard

In February 2020, the NAIC revised the Suitability in Annuity Transactions Model Regulation (#275). A recommendation must now be in the client's best interest, and an agent may not place their own financial interest above that of the client. The regulation introduces obligations of care, disclosure (of the agent's role, remuneration and conflicts of interest), conflict management and written documentation of the basis for a recommendation. According to the NAIC, as of 8 August 2025 the new version had been implemented by 49 jurisdictions. A federal alternative did not materialize: the Department of Labor's 2024 "Retirement Security Rule", which extended fiduciary duties to one-time annuity recommendations, was stayed by the courts and in March 2026 was vacated by a final court ruling in Texas.

Agency consolidation

According to industry estimates, 695 acquisitions of insurance agencies and brokers were announced in the US and Canada in 2025, 12% fewer than in 2024 (787). Buyers backed by private equity accounted for 73% of the deals. The largest were Gallagher's acquisition of AssuredPartners (about USD 13.45 billion, closed in August 2025) and Brown & Brown's acquisition of Accession Risk Management (about USD 9.83 billion, August 2025). In the first half of 2026 the number of deals fell further to 292 (15% fewer than a year earlier), while the share of private equity-backed buyers rose to 76%. The number of independent agencies with revenue of up to USD 1.25 million is estimated at more than 30,000, and consolidation is expected to continue.

What this means for agents

• A single register of intermediaries and electronic processing of appointments show how licensing costs can be reduced without weakening supervision.
• The AI requirements are addressed to insurers, but an agent who uses AI tools should be ready to explain to the client and the regulator how a decision was made.
• The best interest standard makes written justification of a recommendation a mandatory part of selling savings products.
• In consolidation, agencies with a clean client base, transparent reporting and well-established compliance command higher valuations.