State AI Laws, Automated Decisions, and the NAIC Model Bulletin
States enacting AI laws include Colorado (the Colorado AI Act on algorithmic discrimination, enforced by the AG only). New York City's Local Law 144 requires employers using Automated Employment Decision Tools (AEDTs) to obtain a bias audit, publish results, and notify candidates. The NAIC Model Bulletin on the Use of Artificial Intelligence Systems guides insurers and has been adopted by at least 11 states. The Tilting Point Media case settled for $500,000 over COPPA, the CCPA, and the California Age-Appropriate Design Code Act.
States enacting AI legislation include Colorado (the Colorado AI Act on algorithmic discrimination, enforced by the AG only), plus New York, Illinois, Connecticut, Utah, Indiana, Alabama, California, and Texas.
New York City's Local Law 144 requires employers using Automated Employment Decision Tools (AEDTs) for hiring or promotion to have a bias audit conducted, publish the results, and notify candidates (and offer an alternative).
The NAIC Model Bulletin on the Use of Artificial Intelligence Systems guides insurers, emphasizing transparency, accountability, and fairness and requiring AI governance policies and controls; at least 11 states have adopted it. On December 11, 2025, President Trump signed an order directing federal agencies to stop enforcing certain burdensome state AI laws and to discourage new ones, so this area is evolving.
Tilting Point Media, maker of the mobile game SpongeBob: Krusty Cook-Off, had default settings that misclassified children as adults, bypassing parental consent, and shared children's data with third-party SDK providers. It settled for $500,000 for violations of COPPA, the CCPA, and the California Age-Appropriate Design Code Act, and had to implement neutral age gates and SDK transparency.