Image created in Midjourney

Image created in Midjourney

Image created in Midjourney

ECDIS, Regulation, Definitions

What is External Consumer Data?

Insurance regulators have pinpointed external consumer data sources as a concern, both in isolation and in conjunction with AI.

Elaine Gibbs, March 13, 2024

Hand-in-hand with incoming regulations governing the use of AI by insurers are those concerned with the use of external consumer data, or “ECDIS” (short for external consumer data and information sources, coined by Colorado’s SB21-169).

While the definition of AI is tough to pin down, external consumer data may be even more vague. Each piece of regulation has its own list of what’s in and what’s out of scope, presumably heavily negotiated between industry and regulator. Therefore, it’s necessary to consider each regulation on its own.

To that end, we track what’s considered both in and out of scope for external consumer data from various regulations in play, as of March 2024:


  1. Colorado Senate Bill 21-169

  2. Colorado Governance Framework for Life Insurers

  3. Colorado Draft Quantitative Testing for Life Insurers

  4. New York Proposed Insurance Circular Letter

  5. California Bulletin 2022-5

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