Prepare for Colorado SB21-169 with Fruggr
As AI-driven insurance practices face growing regulatory scrutiny, insurers operating in Colorado must now demonstrate that their algorithms and external data sources do not result in unfair discrimination. Fruggr’s Sustainable AI platform gives your organization the governance framework and reporting infrastructure to meet those obligations with confidence.
Colorado SB21-169: Regulation prohibiting unfair discrimination in insurance practices
Colorado Senate Bill 21-169 prohibits insurance companies from using external consumer data and information sources (ECDIS), as well as algorithms and predictive models relying on ECDIS, in ways that result in unfair discrimination against policyholders based on protected characteristics including race, color, national or ethnic origin, religion, sex, sexual orientation, disability, gender identity, and gender expression.
Signed into law on July 6, 2021, the bill directs the Colorado Division of Insurance to adopt sector-specific governance and testing requirements. Regulation 10-1-1, which entered into force on November 14, 2023, currently applies to all life insurers authorized to operate in Colorado. Rulemaking for private passenger auto insurance and health benefit plans is ongoing and expected to finalize in 2025–2026.
Key obligations under Regulation 10-1-1
Insurers in scope must establish a board-overseen governance and risk management framework covering the full lifecycle of any ECDIS, algorithm, or predictive model used in insurance practices — from acquisition and vendor selection through deployment and ongoing monitoring. This includes maintaining a complete, up-to-date inventory of all external data sources and downstream models, along with documented testing results and remediation activities for any identified discriminatory outcomes.
Reporting obligations are continuous: life insurers must submit a progress report to the Colorado Division of Insurance and file an annual attestation signed by a senior officer confirming that the risk management framework is fully implemented. The first full attestation was due December 1, 2024, with annual renewals required thereafter.
How Fruggr supports your compliance with SB21-169
With Fruggr’s Sustainable AI cockpit, insurance companies can build and document their AI governance program directly within the platform mapping all algorithms and external data sources, assigning ownership, tracking review cycles, and maintaining the audit trail required by Regulation 10-1-1. Our automated data collection connects to your existing IT ecosystem, making the initial inventory a matter of hours rather than weeks.
Fruggr’s reporting module transforms your governance data into structured, exportable compliance documentation reducing manual reporting effort by over 60% and giving your compliance and risk teams the evidence they need for annual attestations, board-level oversight, and regulatory examinations by the Colorado Division of Insurance.
