The big picture compliance landscape
The global cyber insurance market reached $15.3 billion USD in 2024 and is expected to more than double by 2030. As this market grows, regulators are tightening rules, expecting insurers to prove their controls and risk management practices are up to the task. Insurance cybersecurity regulations in the United States exist primarily at the state level, which creates overlapping obligations. At the center of this sits the NAIC Insurance Data Security Model Law (NAIC MDL‑668), a model law that states can adopt to provide consistency across jurisdictions. As of mid‑2023, 23 states have adopted legislation based on the Insurance Data Security Model Law.
Beyond the NAIC law, individual states implement their own regulations, and New York’s 23 NYCRR Part 500 is one of the most comprehensive and stringent. It requires insurers to maintain a risk-based cybersecurity program, appoint a Chief Information Security Officer (or equivalent), and submit annual certifications of compliance. The regulation also requires extensive program documentation and continuous proof of compliance.
Most regulations also mandate breach notification requirements. Insurers must notify state insurance commissioners of material cybersecurity events, generally within 72 hours, particularly when breaches affect more than 250 consumers, and provide timely notification to affected consumers when breaches occur. These regulations also establish privacy requirements that govern how insurers collect, use, and protect consumer data.