Colorado Market Audit: Regulation 10-1-1 AI Fairness Act and the July 2026 Algorithmic Underwriting Revolution
Market Disclaimer: This report uses real-time actuarial filings from FSRA (Ontario), Texas Department of Insurance, and FL-OIR for the April 2026 period. It does not constitute legal or licensed insurance advice.
Colorado Regulation 10-1-1 is the most comprehensive state-level restriction on artificial intelligence in insurance underwriting in North America. The regulation, effective July 1, 2026, prohibits unfair discrimination in algorithmic underwriting models, including proxy discrimination where a neutral variable produces discriminatory outcomes through statistical correlation with a protected class. Carriers must file Model Impact Assessments with the CDOI by June 1, 2026, documenting all model variables, protected class correlations, outcome disparity analysis, and remediation plans for any identified discriminatory outcomes. CDOI Consumer Rights Circular CR-26-01 creates a 60-day carrier response obligation for consumer challenges to algorithmic rate decisions.
| Effective Date | July 1, 2026 |
|---|---|
| Carrier Filing Deadline | June 1, 2026 |
| Regulator | Colorado Division of Insurance (CDOI) |
| Legislative Basis | SB 169, 75th Colorado General Assembly |
| Consumer Challenge Period | 60-day carrier response obligation |
| Carriers Pre-Compliant | 7 of 23 as of March 2026 |
| Credit Score Risk Level | High proxy risk; 4 carriers voluntarily suspended |
| Primary Market Shift | Telematics-first underwriting |
Can a Colorado carrier still use my credit score after July 1, 2026?
Regulation 10-1-1 does not categorically ban credit score use in Colorado auto insurance rating. It prohibits models that produce discriminatory outcomes. Credit score has been identified in CDOI March 2026 model audit reviews as carrying high proxy discrimination risk for race and disability status in the Colorado portfolio. Carriers must demonstrate through their Model Impact Assessment that their specific use of credit score does not produce discriminatory outcomes. At least four major Colorado carriers have voluntarily suspended credit score as a primary rating variable ahead of the July 1 compliance deadline.