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New Jersey's AI Claims-Denial Bill: What Insurers Should Do Now

Written by David Cockrum | Oct 1, 2026, 3:20:51 PM

Quick Answer

New Jersey Assembly Bill A5494, introduced September 14, 2026, would bar insurers from using artificial intelligence to make the final decision to deny an auto, homeowners or flood claim, with penalties of up to $5,000 per violation. It is still in committee. For P&C carriers, MGAs and TPAs, the useful response is the same whether or not it passes: know where AI touches claim decisions, make sure a qualified person owns every denial, and keep an audit trail an examiner can follow. Vantage Point helps insurers build those controls into their claims workflows.

Status as of September 23, 2026: introduced and referred to the Assembly Science, Innovation and Technology Committee. No hearing, amendment or vote is recorded, and no Senate companion is listed.

This article is general information, not legal advice. Confirm how A5494 would apply to your company with counsel.

Key Takeaways (TL;DR)

  • What it is: A5494 would bar insurers from letting AI make the final decision to deny an auto, homeowners or flood claim in New Jersey.
  • What it doesn't do: As introduced, it doesn't ban AI in claims. The prohibition targets the final denial, not intake, triage, fraud flags or payments.
  • Where it stands: in committee since September 14, with no further action as of September 23, 2026.
  • Why it matters: New Jersey already expects insurers to run a written AI governance program. A5494 would add a hard rule about who decides a denial.
  • What to do now: inventory claims AI, put an accountable person on every denial, and log each decision so it can be reconstructed.

What Happened: New Jersey Filed a Bill on AI Claim Denials

New Jersey lawmakers have filed a bill that would bar insurers from using AI to deny auto, homeowners and flood claims. It's still in committee, which makes now the cheapest time for carriers to document where AI touches their claim decisions.

Assemblyman Chris Tully (D-38) introduced Assembly Bill A5494 on September 14, 2026. It was referred the same day to the Assembly Science, Innovation and Technology Committee. Repairer Driven News reported the bill on September 18, and other trade outlets followed.

The bill is two pages long. The details that matter for claims operations are in its exact wording.

What Would New Jersey's A5494 Do?

Every fact below comes from the introduced bill text and the NJ Legislature bill page, checked September 23, 2026.

Item What the bill says
Bill New Jersey Assembly Bill A5494, 2026–2027 session
Sponsor Assemblyman Chris Tully, District 38 (Bergen)
Introduced September 14, 2026
Referred September 14, 2026, to the Assembly Science, Innovation and Technology Committee
Lines covered Automobile, homeowners and flood insurance
What it bars An insurer "shall not use artificial intelligence to make the final decision to deny a claim"
Penalty Up to $5,000 for each violation, collected in a summary proceeding
Effective date Immediately upon enactment
Current status In committee; no hearing, amendment or vote recorded; certified for a fiscal note; no Senate companion listed (as of September 23, 2026)

"Final decision" is the phrase that matters

The bill doesn't ban AI in claims. It bars AI from making the final decision to deny. As written, AI could still score, flag or recommend, as long as it isn't the thing that makes the denial call.

The sponsor's statement goes further. It describes the bill as "requiring a claims adjuster or investigator to review" denied claims. The operative text, though, doesn't set out a review procedure, reviewer qualifications or documentation rules. Those are the details most likely to be added or argued over if the bill moves.

The AI definition is narrower than you might expect

A5494 defines artificial intelligence as a system that is trained on data, is designed to simulate human communication through text, audio or visual communication, and generates non-scripted outputs with limited or no human oversight. That reads closest to generative and conversational AI. Whether it would reach a traditional predictive model or a rules engine is unclear, and definitions often change in committee.

Don't plan around the narrow reading. New Jersey's existing insurance guidance, covered below, defines AI far more broadly.

What the bill doesn't address

The text is silent on partial denials, reduced payments, underwriting and claim approvals. Florida's 2026 proposal, by contrast, expressly covered denying part of a claim and reducing a payment. If A5494 is amended, those are the gaps to watch.

Who Would A5494 Affect?

  • Carriers writing auto, homeowners or flood in New Jersey. The bill defines an insurer as anyone engaged in that business in the state. Carriers hold the obligation and the penalty exposure.
  • MGAs and TPAs that handle claims for those carriers. The text doesn't name them. But a denial issued for a carrier is still that carrier's denial, so expect carriers to push matching requirements into delegated-authority and claims-service agreements.
  • Claims-platform and insurtech vendors with embedded AI. Carriers will ask what the AI does, where a person signs off and what gets logged.
  • Agencies, indirectly. Policyholders who see the headlines may ask their agent whether AI denied their claim. Agencies will need a plain answer from their carriers.

Why Does It Matter Beyond New Jersey?

A5494 is one bill in one state, and it may change or stall. The direction is the point: rules are moving from general AI governance toward a narrower question about who makes an adverse claim decision.

New Jersey already has AI guidance for insurers

On February 11, 2025, the New Jersey Department of Banking and Insurance (DOBI) issued Bulletin No. 25-03 on the use of AI systems in insurance. It expects insurers to maintain a written AI Systems (AIS) Program covering governance, risk management controls and internal audit. That program should span the insurance life cycle, including claim administration, payment and fraud detection, and cover AI supplied by third-party vendors. The bulletin also lists "the extent to which humans are involved in the final decision-making process" as a risk factor, and it defines an AI system broadly as a machine-based system that generates outputs such as predictions, recommendations or content.

A5494 would put a hard rule on top of that guidance. The move is from guidance to prohibition, aimed at the moment a claim is denied.

The NAIC model bulletin set the baseline

NAIC members adopted the Model Bulletin on the Use of Artificial Intelligence Systems by Insurers in December 2023. It is guidance rather than a model law. It calls for a written AIS Program matched to risk, governance of third-party AI, and documentation that regulators may request during an exam. New Jersey's bulletin follows the same structure.

Florida and health insurance point the same way

Florida's 2026 HB 527, titled "Mandatory Human Reviews of Insurance Claim Denials," would have required qualified human professionals to make decisions to deny or reduce claims. It passed the Florida House 108–0 on March 5, 2026, then died in the Senate Rules Committee on March 13, when the session ended. The Senate version, SB 202, died in committee the same day.

In health insurance, California's SB 1120, signed in September 2024, requires that medical-necessity denials be made only by a licensed physician or licensed health care professional, even when plans use AI tools for utilization review. Across these efforts the idea is the same: a qualified, accountable person owns the adverse decision.

For a broader view of how AI is changing claims and underwriting, see our insurtech trends overview for 2026. This post stays focused on one bill and the readiness steps it points to.

What Should Insurers Do Now to Prepare?

The readiness work is the same whether or not A5494 passes, and much of it is already expected under Bulletin 25-03. It comes down to three things: know every place AI touches a claim decision, make sure a qualified person owns every denial, and keep a per-claim record an examiner can follow.

Action Why it matters Typical owner
Inventory AI across the claims lifecycle Include AI embedded in vendor claims platforms, estimating tools and chat channels that nobody logged as "AI." You can't control what you haven't found. CIO with claims operations
Classify which decisions can produce a denial Separate AI that supports intake, triage, fraud flags or fast-track payments from AI that can drive a full or partial denial. The bill aims at the second group. Claims leadership with compliance
Design human review with real authority The reviewer must be able to override the recommendation, and the workflow shouldn't let a denial go out without that step. Rubber-stamp reviews are the weak point. Head of claims
Log a per-claim audit trail Capture model and version, inputs, the AI recommendation, the reviewer, the final decision and the rationale, so any denial can be reconstructed. CIO or claims systems owner
Tighten vendor contracts Require disclosure of AI use, notice before model changes, and audit and regulatory-cooperation rights. Bulletin 25-03 expects insurers to oversee third-party AI. Procurement with legal
Have people write denial reasons The adjuster who makes the decision should write or confirm the reasons in the denial letter rather than pass along model output. Head of claims
Align governance with your AIS Program Map these controls to the written program DOBI's NAIC-based bulletin expects, so new rules become updates rather than rebuilds. CCO or chief risk officer
Track bills in every state you write Watch status, companion bills and amendments across your footprint, not just New Jersey. Compliance or government affairs

Vendor terms are often the slowest item to fix. Our guide to the AI inside your vendor contracts covers the clause-level detail.

A5494 Status: What's Known and What to Watch

What we know (as of September 23, 2026)

  • The bill text, sponsor, covered lines, penalty and immediate effective date.
  • It was introduced and referred on September 14 and has had no action since.
  • The legislative calendar posted September 22 lists no hearing on it, and no Senate companion is listed.

What we don't know

  • Whether the committee will take it up, and when.
  • Whether the AI definition or scope will change, for example to cover partial denials or payment reductions.
  • How "final decision" would be interpreted in practice.

Triggers to watch

  • A committee hearing or vote on A5494.
  • A companion bill in the New Jersey Senate.
  • A similar bill filed in another state.
  • New DOBI guidance on AI in claims handling.

How Vantage Point Helps

Vantage Point helps P&C carriers, MGAs and TPAs design claims workflows where AI assists and people decide. On Salesforce, that means claims processes with a required human approval step before any denial is issued, per-claim audit history, AI governance mapped to your AIS Program, and integration with core claims and policy systems so the decision record is complete.

Our compliance and security solutions cover governance and audit-trail design. Our workflow automation and process optimization practice builds the review routing and approval steps. Our insurance industry team brings the claims context. Senior consultants only — no junior handoffs; the experts you meet are the experts who deliver.

Vantage Point has completed 400+ engagements for 150+ clients, with 95% client retention and a 4.71/5.0 average engagement rating.

Frequently Asked Questions

What is New Jersey Assembly Bill A5494?

A5494 is a New Jersey bill introduced on September 14, 2026, by Assemblyman Chris Tully. It would bar insurers from using artificial intelligence to make the final decision to deny an auto, homeowners or flood insurance claim, with penalties of up to $5,000 per violation.

Does A5494 ban AI in insurance claims?

No. As introduced, it targets only the final decision to deny a claim. It doesn't address AI used for intake, triage, fraud flags or payments, so AI could still assist as long as it doesn't make the final denial call.

Does A5494 require a human reviewer?

The operative text bars AI from making the final denial decision but doesn't set out a review procedure. The sponsor's statement describes the bill as requiring a claims adjuster or investigator to review claims. In practice, a person would need to make and own each denial.

Which insurers would A5494 cover?

It defines an insurer as a person engaged in the business of homeowners, flood or automobile insurance in New Jersey. Other lines aren't included. The text doesn't separately name MGAs, TPAs or claims vendors.

Has A5494 passed?

No. As of September 23, 2026, it has been introduced and referred to the Assembly Science, Innovation and Technology Committee, with no hearing, amendment or vote recorded and no Senate companion listed. If enacted, it would take effect immediately.

Does New Jersey already regulate insurers' use of AI?

Yes, through guidance. DOBI Bulletin No. 25-03, issued February 11, 2025, expects insurers to maintain a written program for the responsible use of AI systems, oversee AI from third-party vendors and be ready to document their use of AI during investigations and exams.

What should insurers do now?

Inventory where AI touches claim decisions, including inside vendor platforms. Make sure a qualified person makes and documents every denial, keep a per-claim audit trail and update vendor contracts. That work also supports DOBI's existing expectations.

Resources

Find Out Where AI Touches Your Claim Decisions

Whether or not A5494 moves, an AI-in-claims inventory and a human-review design are worth doing now. Vantage Point's senior consultants can map where AI influences your claim decisions, identify which steps can lead to a denial, and build the approval and audit-trail controls into your claims workflow.

Talk to Vantage Point about a claims AI readiness review

This article is general information, not legal advice, and reflects the status of A5494 as of September 23, 2026. Vantage Point is a CRM consulting firm helping businesses transform with Salesforce, HubSpot and AI.