New York Assembly Bill A.10364: How Telematics Transparency Legislation Could Reshape Commercial Fleet Insurance Nationwide

Fleet insurance premiums hit a record $0.102 per mile in 2024, and commercial auto rates climbed another 8.8% in Q2 2025 alone. For fleet operators watching insurance consume 8–15% of their operating budgets, telematics has emerged as the most powerful tool for fighting back—with equipped fleets securing 15–30% premium reductions while unequipped competitors face double-digit increases.

But here's the catch: nobody outside the insurance industry truly understands how telematics data translates into those premium calculations. That's about to change. New York's Assembly Bill A.10364, introduced on March 2, 2026, could force insurers to open the black box of algorithmic pricing—and the ripple effects for commercial fleet operators nationwide would be enormous.

What Bill A.10364 Actually Proposes

Introduced by Assembly Member Charles Lavine and referred to the Assembly Committee on Insurance, A.10364 targets the opaque relationship between telematics data collection and insurance pricing decisions. The bill's core requirements include:

• Algorithm disclosure: Insurers must publicly disclose how their telematics scoring systems work, including which factors feed into pricing models—a direct challenge to methodologies long treated as closely guarded trade secrets.
• Risk relevance proof: Both insurers and third-party telematics vendors must demonstrate to state regulators that every factor in their pricing models is genuinely tied to actuarial risk.
• Data use restrictions: Information collected through telematics can only be used for underwriting and rating decisions—no repurposing for marketing or other commercial purposes.
• Anti-discrimination protections: Algorithms and predictive models are explicitly barred from discriminating based on race, color, national origin, religion, sex, sexual orientation, disability, gender identity, or gender expression—even indirectly through proxy variables.
• Consumer data access: Drivers gain the right to request and receive all data collected about them in a readable format.

Perhaps most significantly, the bill reclassifies third-party telematics vendors as "rate service organizations" under New York Insurance Law, bringing them under direct regulatory oversight and requiring them to file their models and algorithms with the superintendent of insurance.

If signed into law, it takes effect just 90 days after enactment.

Why This Matters for Commercial Fleet Operators

The insurance telematics market is exploding. According to Mordor Intelligence, the market will reach 278 million active telematics policies in 2026, growing at a 28.85% CAGR through 2031 when it's projected to hit 988.8 million active premiums. The fleet segment is growing fastest at 31.4% annually.

For trucking and logistics companies, telematics-based insurance isn't optional anymore—it's becoming table stakes. Many major insurers now mandate telematics and dashcam technology just to receive a quote. Fleets that refuse adoption are finding themselves with fewer carriers willing to write coverage at all, according to FreightWaves reporting on the consolidating trucking insurance market.

But here's where the transparency gap creates real problems:

The Pricing Black Box

Today, a fleet operator might install telematics across their entire operation, invest in driver coaching programs, and see measurable safety improvements—only to receive a renewal quote with an unexplained premium increase. Without visibility into how insurers weight different telematics metrics, fleet managers are essentially optimizing blind.

The five metrics insurers care about most—hard braking frequency, following distance, speeding, distracted driving, and time-of-day driving patterns—are well known. But the relative weighting of each metric, the algorithms combining them, and how third-party data sources supplement telematics readings remain entirely proprietary.

The Discrimination Concern

As AI-driven underwriting models grow more sophisticated, they ingest increasingly diverse data sources beyond direct telematics readings. ZIP code data, route patterns, delivery neighborhoods, and even fuel purchase locations can serve as proxy variables that produce discriminatory pricing outcomes—even when the algorithm doesn't explicitly consider protected characteristics.

A.10364's requirement that insurers prove their models don't produce discriminatory outcomes, even indirectly, addresses a concern that fleet operators in diverse metropolitan areas have raised for years: that operating routes through certain neighborhoods shouldn't inflate premiums when the fleet's actual safety record is strong.

The State-by-State Regulatory Momentum

New York has historically set the tone for insurance regulation nationwide, and A.10364 follows a pattern of state-level action on algorithmic transparency:

• Colorado enacted comprehensive AI insurance regulations in 2024, requiring insurers to test algorithms for unfair discrimination.
• Connecticut passed legislation requiring insurers to disclose AI usage in underwriting decisions.
• California's Department of Insurance has been developing its own framework for algorithmic accountability in pricing.

At the federal level, the National Association of Insurance Commissioners (NAIC) has been developing model guidance on AI and predictive analytics in insurance, but binding federal standards remain years away. State legislation like A.10364 is filling the regulatory vacuum.

For fleet operators spanning multiple states, this patchwork creates complexity—but also opportunity. Carriers that build robust telematics data strategies now will be positioned to demonstrate compliance and negotiate better rates regardless of which state framework applies.

What Fleet Operators Should Do Now

Whether or not A.10364 passes in its current form, the direction of travel is clear: telematics transparency in insurance pricing is coming. Here's how fleet operators should prepare:

1. Audit Your Telematics Data Strategy

Understand exactly what data your telematics systems collect, how it's stored, and who has access. Under emerging transparency frameworks, the data your fleet generates becomes a negotiating asset—but only if you control it.

2. Demand Scoring Transparency at Renewal

Even before legislation mandates it, fleet operators should push their brokers and insurers to explain how telematics data influences premium calculations. Carriers that can demonstrate consistent safety improvements across key metrics—hard braking events below 2 per 1,000 miles, speed compliance above 95%, zero-tolerance distracted driving policies—should be rewarded transparently.

3. Document Everything for Dispute Resolution

As transparency requirements expand, historical telematics data becomes evidence. Fleets that maintain clean, auditable records of driver behavior improvements will have leverage to challenge premium increases that don't align with their risk profile.

4. Evaluate Your Technology Stack

With third-party telematics vendors facing potential regulatory classification as rate service organizations, the vendor you choose matters more than ever. Prioritize vendors with clear data governance policies, algorithmic transparency commitments, and the willingness to share their scoring methodologies.

How CXTMS Helps Fleets Navigate the Telematics-Insurance Landscape

The intersection of telematics data, insurance pricing, and regulatory compliance creates a complex optimization problem that spans operations, finance, and legal. CXTMS provides fleet operators with the analytics infrastructure to turn telematics data into actionable insurance strategy:

• Carrier risk profiling that evaluates insurance stability, safety records, and telematics adoption across your carrier network
• Fleet analytics dashboards that consolidate telematics data from multiple providers into a single view of fleet safety performance
• Cost modeling tools that help quantify the insurance premium impact of operational decisions—route changes, driver assignments, and equipment upgrades
• Compliance tracking that monitors evolving state-by-state regulatory requirements for telematics data usage and algorithmic transparency

The era of opaque fleet insurance pricing is ending. Whether driven by legislation like A.10364 or by market forces pushing telematics adoption past the tipping point, transparency is coming—and the fleets that embrace it will pay less while their competitors pay more.

Ready to turn your fleet's telematics data into insurance savings? Request a CXTMS demo today and see how our platform connects operational safety data to financial outcomes.