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The Fourteen States That License Body Shops, Compared: What a Licence Actually Proves

Short answer: fourteen states require a motor vehicle repair shop to hold a state licence or registration: California, Connecticut, Florida, Hawaii, Illinois, Massachusetts, Michigan, Missouri, Nevada, New Jersey, New York, Ohio, Rhode Island and Utah. No two of those licences prove the same thing. In the other 36 there is nothing of that kind to check, and they are named below rather than left as a number. The District of Columbia is the fifty-first jurisdiction and belongs in neither group: it had a repair licence and repealed it in 2025. And among the fourteen, no two licences prove the same thing: different regulators, different statutes, and in three of them the licence is not about collision work at all.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-08-20 · How this was written, and what the machine may not do

How this page was produced: Researched, drafted and checked with AI assistance under human direction, and signed off by the named author. How this site is written

If you take one thing from this page: "licensed" is not a grade. It is a receipt from one particular agency for one particular thing, and what that thing is changes at the state line.

Two things this page does that a count alone cannot. It shows you where the licence hides, because in Illinois and Missouri it is filed under salvage and scrap. And it lists the credentials that look like a body-shop licence and are not, because those are what produce the higher numbers you will find elsewhere.

The fourteen, side by side

StateRegulatorAuthorityWhat it actually covers
California #Bureau of Automotive RepairCal. Bus. & Prof. Code § 9884.6 (Automotive Repair Dealer)Every business repairing vehicles for compensation, not collision-specific
Connecticut #Department of Motor VehiclesConn. Gen. Stat. § 14-52(a), "repairer" and "limited repairer" defined at § 14-51Repairers and limited repairers, two different things
Florida #Department of Agriculture and Consumer ServicesFla. Stat. § 559.904(1), Motor Vehicle Repair Act (§§ 559.901-559.9221)Every repair shop. A registration, not a licence. § 559.903 names paint and body shops in the definition
Hawaii #Motor Vehicle Repair Industry Board, Department of Commerce and Consumer AffairsHRS § 437B-7Every person repairing vehicles for compensation. Licenses the dealer and the mechanic
Illinois #Secretary of State625 ILCS 5/5-301(a), "repairer" defined at 5/1-171.3A repairer licence, filed in the salvage-trade chapter but defined as work on essential parts: quarter panels, fenders, doors, hoods, deck lids, bumpers
Massachusetts #Division of StandardsM.G.L. c. 100A, § 2Auto body shops. A registration
Michigan #Department of StateMCL § 257.1306, in the Motor Vehicle Service and Repair Act (Act 300 of 1974)Maintenance, diagnosis, body work and repair, under one registration
Missouri #Department of RevenueRSMo § 301.218.1(3), "body shop" defined at § 301.010"Body shop" is a named licence class. Triggered at four or more wrecked vehicles a year. Franchised-dealer body shops are exempt
Nevada #Department of Motor VehiclesNRS § 487.610 (body shop) and NRS § 487.560(1) (garage)Two separate credentials. The body shop licence is the collision one. The garage registration is mechanical, and its statutory list does not mention body work
New Jersey #New Jersey Motor Vehicle CommissionN.J.S.A. § 39:13-2(b)Auto body facilities specifically
New York #Department of Motor VehiclesN.Y. Veh. & Traf. Law § 398-cRS is repair; RSB is the body-shop class. Both are DMV classes, not statutory ones
Ohio #Motor Vehicle Repair BoardORC § 4775.02Collision shops, via a dedicated board
Rhode Island #Department of Business RegulationR.I. Gen. Laws § 5-38-4, rules at 230-RICR-30-05-2Six licence types, not two. Class A and Class B permit identical work and differ only in the bar you clear
Utah #Motor Vehicle Enforcement Division, State Tax CommissionUtah Code § 41-3-201(2)(l)"Body shop" is its own licence class, listed beside dealer and dismantler

Note what that table does to a simple question. If you ask "is this shop licensed?" in California, Florida or Hawaii, a yes tells you the business is a registered repair operation. It tells you nothing about collision capability, because the same credential covers the transmission shop and the oil-change bay. In Ohio, Nevada or Utah, the same yes means something much narrower and much more useful.

Where the licence hides: Illinois and Missouri file it under salvage

Both of these were missing from this page until this week, and they went missing for the same reason. Put the two operative sentences side by side.

Illinois, 625 ILCS 5/5-301(a): "No person in this State shall, except as an incident to the servicing of vehicles, carry on or conduct the business of an automotive parts recycler, a scrap processor, a repairer, or a rebuilder, unless licensed to do so in writing by the Secretary of State under this Section."

Missouri, RSMo § 301.218.1: "No person shall, except as an incident to the sale, repair, rebuilding or servicing of vehicles by a licensed franchised motor vehicle dealer, carry on or conduct the following business unless licensed to do so by the department of revenue... (3) Rebuilding and repairing four or more wrecked or dismantled vehicles in a calendar year as a rebuilder or body shop."

Same opening. Same structure. Same neighbours: parts recyclers, scrap processors, dismantlers. If you are looking for body-shop regulation you do not look in the wrecking-yard statute, and that is exactly where both states put it.

And in both, the definitions section says the opposite of what the neighbours imply.

Illinois defines a repairer at 5/1-171.3 as one who restores a vehicle "other than a vehicle for which a salvage certificate has been issued" by "restoring, mending, straightening, replacing, altering, or painting its essential parts." Salvage work is the rebuilder's category. The repairer is defined against salvage.

Missouri does it even more plainly. RSMo § 301.010 defines "Body shop" as "a business that repairs physical damage on motor vehicles that are not owned by the shop or its officers or employees by mending, straightening, replacing body parts, or painting." And "Rebuilder" as "a business that repairs or rebuilds motor vehicles owned by the rebuilder." Customer's car, you are a body shop. Your own car, you are a rebuilder. Missouri then requires the Director of Revenue to "issue a separate license for each kind of business... to be entitled and designated as either 'used parts dealer'; 'salvage dealer or dismantler'; 'rebuilder or body shop'; or 'scrap processor' license."

So the lesson for anyone doing this research is a search instruction, not a fact. Do not search a state's code for "body shop licence." Search the salvage, wrecking and dismantling chapter and read its definitions section. Two of the fourteen are only findable that way, and both of them were missed here by people who had already read the vehicle code.

Missouri's threshold matters and is easy to state. The licence attaches at four or more wrecked or dismantled vehicles in a calendar year. Any commercial collision shop clears that in a week, so as a practical matter it is a body-shop licence. As a legal matter it is a threshold, and a shop that repairs three does not need it. A body shop operating as part of a licensed franchised motor vehicle dealer is exempt by the opening clause.

Credentials that look like a body-shop licence and are not

This is the section that explains why published counts differ, and it is the part we would want if we were the ones checking. Every row below is a real, current, state-issued credential that a body shop may have to hold. None of them is a licence to operate as a body shop. Count them and you climb into the thirties honestly.

StateThe thingWhat it actually is
AlabamaCode of Ala. § 40-12-54, "Automobile garages and shops"A head tax. $7.50 for the first man, $7.50 per additional man, in Title 40 Revenue and Taxation, bought at the county probate office
Arkansas8 CAR § 64-609, titled "Auto repair shops"A tire rim-removal fee rule, plus tire-programme registration
Kentucky103 KAR 27:230, titled "Motor vehicle body shops"A Department of Revenue sales-tax interpretation. Title 103 is Revenue
LouisianaR.S. 32:1254(A)(7), "Satellite warranty and repair centers"A real repair-facility licence, but only for an off-dealer-premises facility a manufacturer has approved to do warranty work. See below
MarylandMd. Bus. Reg. § 17-802, "must have a garage license"§ 17-801(b) defines garage as a place where vehicles are "stored or parked for a fee." § 17-803 discounts machine-shop floor area out of it
NebraskaNeb. Rev. Stat. § 60-377, "registration certificate and one license plate"A plate. It reaches only vehicles "which are not registered and which are not owned by" the shop, and the plate is for moving them
New HampshireRSA 261:136, "Application for Repairer Registration"Permissive. A repairer "may make application... for a general distinguishing number and for a supplemental repair plate"
OregonDEQ Basic Auto Body PermitAn air permit, for shops painting more than 25 vehicles a year inside the Portland air quality maintenance area
Pennsylvania75 Pa.C.S. § 1337, Miscellaneous Motor Vehicle BusinessA registration-plate class that happens to name repair and towing among qualifying activities
Texas30 TAC § 106.436A TCEQ air permit by rule for surface coating
WashingtonRCW 46.71.090, which says "registration certificate"It points at the Department of Revenue tax registration under RCW 82.32.030. Ch. 46.71 creates no credential of its own, though it does impose real repair duties: see RCW 46.71.025 in the table below
Maine29-A M.R.S. § 1762: the State Police "may license garages"Inspection-station licensing

Three of those deserve a sentence each, because they are the ones most likely to be argued.

Louisiana is a genuine partial yes and we say so here first. R.S. 32:1254(A) lists nineteen categories that "shall be licensed by the commission in order to engage in business," and item (7) is satellite warranty and repair centers, defined at R.S. 32:1252 as "a motor vehicle repair facility, other than at a motor vehicle dealer franchised location, approved by a manufacturer or distributor and authorized to perform warranty and other repairs." An independent collision shop with no manufacturer authorisation is outside it. An OEM-approved off-site warranty centre is inside it. That is a real state licence covering a real slice of repair work, and Louisiana stays in the no-general-licence group only because the slice is defined by manufacturer approval. Doing collision repair does not by itself trigger it.

New Hampshire is the sharpest near-miss. The statute is captioned "Application for Repairer Registration," it sits in a subdivision headed "Registration by Repairers," and the DMV runs it as a Repair Dealer programme with real conditions attached. But 261:136 says "may make application," and what it issues is a distinguishing number and repair plates. The same chapter contains a section captioned "Dealer License Required," so New Hampshire plainly knows how to write a mandate and did not write one here. A shop that never moves an unregistered customer car on the road needs nothing.

Maryland is the best cautionary tale of the group, because "garage license" is exactly the phrase a researcher would search for, it is mandatory, it is state-issued, and it is about parking.

Four states answer the question in their own words

A failure to find is weak evidence. A state saying so is not. Four of the 36 say it directly.

Texas, from the DMV's own consumer guide: "In Texas, the state or local government does not license repair shops. There is not a test a mechanic must take before he opens a shop to perform motor vehicle repairs."

Kansas, from the Kansas Business One Stop starter kit for auto repair: "Generally, the State of Kansas does not require specific licenses or permits for an auto repair shop." It adds that owners should check with their city or county, which is the municipal carve-out being stated by the state itself.

Oklahoma, from the state business portal, which files auto repair under a heading reading "Common Business Activities Without License Requirements": "These common business activities do not require a state license. However, licenses for these activities may still be required by counties and municipalities." Under that heading, "Repair & Installation Services" includes "Automotive, Truck, & Engine."

Pennsylvania, from the state business hub page for auto mechanics and garages, after listing sales tax and conditional inspection-station registration: "Besides the items mentioned above, there are no other requirements for an auto mechanic, garage, or similar business."

And South Carolina considered it twice and declined. S.912 in 2011-12 and S.860 in 2023-24 would each have imposed written-estimate, aftermarket-parts-disclosure and parts-return duties on motor vehicle repair facilities. Both were referred to the Committee on Transportation and neither was enacted. A legislature that looked at the question and did not act is stronger evidence than silence.

Why other sources say 34

A figure of 34 states with repair licensing or registration circulates widely and is easy to find. We could not stand it up.

The most-cited version appears on a commercial reference site operated by Authority Network America LLC, which attributes it to the Automotive Service Association's 2022 regulatory survey. We could not locate that survey on the ASA's own site. The page carrying the figure describes itself in its own footer as "Reference information only." We are not calling the number false. We are saying we could not get from it to a state, a statute and a regulator, which is the only form in which this page will publish anything.

The table two sections up is the mechanical explanation. Count occupational tax stamps, air permits, sales-tax registrations, plate classes and every separate credential a state issues, and the thirties are reachable without anyone lying. Count what this page counts, which is a state credential you must hold to operate a motor vehicle repair business and that the state can take away, and you get fourteen.

Neither count is dishonest. They answer different questions. Ours is the question a person asks standing in front of a shop: is there a state record saying this business is allowed to do this work, and can I go and read it. If you want a different question answered, the citations here are enough to recount the list yourself, which is the point of printing them.

Four things that vary, and all of them matter

1. Who regulates it says what they care about. Four states use the DMV. Ohio built a dedicated Motor Vehicle Repair Board and Hawaii a Motor Vehicle Repair Industry Board. Massachusetts uses the Division of Standards, the same body that checks weights and measures. Florida uses the Department of Agriculture and Consumer Services. Illinois uses the Secretary of State. Missouri and Utah both put it inside the tax authority, the Department of Revenue and the State Tax Commission respectively. A licence issued by a weights-and-measures authority, a revenue department and a collision-specific board are not measuring the same thing, whatever all three are called on a shop wall.

2. Licence or registration is a real distinction, not wording. Massachusetts, Florida and Michigan register; the others licence. Registration generally means you told the state you exist and met a filing requirement. Licensure generally implies the state assessed something first. Neither is worthless and neither is a competence test, but they are different claims.

3. Some states subdivide, and the subdivision is the whole answer. Rhode Island issues six types. Connecticut separates repairers from limited repairers. New York separates RS from RSB. Nevada issues a body shop licence and a garage registration covering different trades. Missouri issues four classes under one section and body shop is one of them. Hawaii licences the dealer and the mechanic separately. In each case a shop can hold the credential and still be outside the category you care about. "Licensed in Rhode Island" is not an answer; the class is.

4. What happens to a licence when it lapses is not standard. New York keeps expired records visible for about six years, so a lapse is legible. New Jersey's expired licences simply drop off the published roster, so a shop that lost its licence and a shop that never had one look identical from outside. Ohio distinguishes Inactive from Closed. Connecticut publishes a download, so there is no live lookup at all.

That fourth point is the one that catches people. An absence from a register is not evidence of anything unless you know how that register handles absence.

Rhode Island issues six licences, and two of them permit the same work

Under 230-RICR-30-05-2 the Department of Business Regulation issues a Full Collision Repair License Class A (§ 2.5), a Full Collision Repair License Class B (§ 2.6), a Limited Heavy Truck and Equipment License (§ 2.8), a Limited Paint, Restoration and Customization License (§ 2.9), Special Use Licenses including paintless dent repair (§ 2.10), and a Salvage Vehicle Repair License (§ 2.11) that is an add-on.

Now read what A and B actually permit. Class A "permits a Licensee to perform all types of Motor Vehicle Body Work." Class B "permits a Licensee to perform all types of Motor Vehicle Body Work." The permitted scope is identical. The difference is the bar: a Class A applicant must show certification for the repair and refinishing of aluminum, high strength steel, and other metal or alloy, and must certify its technicians across all seven categories the rules list, or hold I-CAR Gold Class recognition.

So Rhode Island is the one place on this table where the class letter is close to a competence grade, where elsewhere it marks scope, and the one place where reading only "licensed" throws away nearly all of the information the state collected.

The District of Columbia, which had one and repealed it

DC is the fifty-first jurisdiction and it does not fit either column.

It used to have a repair-specific licence. D.C. Code § 47-2832, "Repairing of motor vehicles", is repealed. The repeal came in § 5(b) of D.C. Law 24-333, and § 7286 of D.C. Law 25-217 made it applicable as of 1 October 2025. What is left is an endorsement on the general Basic Business License, Consumer Goods (Auto Repair), whose scope is the repair, servicing, alteration, restoration, towing, painting, cleaning, finishing or parking of vehicles. Collision work is inside that description and so is a parking lot.

So a DC shop can hold a current business licence that says nothing whatever about repair capability, and the credential that once meant something specific stopped existing less than a year ago. If you are reading a DC record dated before October 2025, you are reading a different regime from the one in force now.

The other 36 states

No repair-shop licence or registration. A shop there may be perfectly good, and there is simply no state credential of that kind to check. Verification has to come from somewhere else: federal and environmental filings, business-entity records, manufacturer certification programmes, which are the sources we use to build records in those states.

They are: Alabama, Alaska, Arizona, Arkansas, Colorado, Delaware, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Minnesota, Mississippi, Montana, Nebraska, New Hampshire, New Mexico, North Carolina, North Dakota, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Vermont, Virginia, Washington, West Virginia, Wisconsin and Wyoming.

Read that list for what it is. For each we ran keyword searches in several phrasings, then took every candidate to the state's own site. That is stronger than our first pass and it is still a failure to find. We have not verified the absence. It is listed state by state so that anyone who knows better can tell us which one we missed, which a collective "the other 41" made impossible. It made it impossible for us too: five of the states that used to sit inside that number did have one.

No licence does not mean no law. Every one of the 36 has something, and the next section gives the citation for all of them.

North Carolina is the clearest example: N.C.G.S. Article 15B defines a motor vehicle repair shop in terms that expressly reach paint and body shops, then imposes estimates, invoices, signage and prohibited-act duties, and creates no credential at all. A definition confers no licence.

This is worth saying plainly because the alternative is a bad inference: shops in the 36 are not unlicensed in any meaningful sense. There is nothing to be licensed by.

What law does apply in the 36, state by state

A list of names is a weaker thing than a list of citations, so here is the citation. For each of the 36 states with no repair-shop licence, this is the law that actually governs the repair transaction, or the nearest thing to it.

Read the confidence column before you rely on any row. Three tiers, and we are not going to blur them:

StateCitationWhat kind of lawConfidence
AlabamaAla. Code § 32-17A-3, "Disclosure Document"Aftermarket crash parts disclosureRead
AlaskaAS 45.45.130 to 45.45.240, Alaska Automobile Repair ActRepair statuteRead
ArizonaA.R.S. § 20-461(A)(16)Aftermarket parts notice, insurer dutyRead
ArkansasArk. Code Ann. §§ 4-90-305, 4-90-306Aftermarket crash parts disclosureRead (as enacted)
ColoradoC.R.S. §§ 42-9-101 to 42-9-113, Motor Vehicle Repair ActRepair statuteRead
Delaware6 Del. C. §§ 4901A to 4909A, Auto Repair Fraud PreventionRepair statuteRead
GeorgiaO.C.G.A. §§ 10-1-390 to 10-1-408, Fair Business Practices ActGeneral UDAP onlyRead
IdahoIDAPA 04.02.01.120 to .132Repair regulation, goods generallyRead
IndianaInd. Code § 24-5-0.5-3(b)(12), (b)(13)Repair provisions inside the UDAPRead
IowaIowa Code § 537B.3, Motor Vehicle Service Trade PracticesRepair statuteRead
KansasK.S.A. § 50-662Aftermarket parts, binds the estimatorRead
Kentucky806 KAR 12:095, Section 8Repair regulation, insurer-directedRead
LouisianaR.S. 32:1254(A) chapeau, item (7)Licensing, satellite warranty centres onlyRead
Maine29-A M.R.S. § 1804Repair statuteRead
MarylandMd. Code Ann., Com. Law § 14-1002, Automotive Repair FacilitiesRepair statuteRead
MinnesotaMinn. Stat. §§ 325F.56 to 325F.66, Truth in Repairs ActRepair statuteRead
MississippiMiss. Code Ann. § 63-27-5Aftermarket crash parts disclosureLead
MontanaMont. Admin. R. 23.19.202, "Repairs, estimates and invoices"Repair regulationRead (as adopted)
Nebraska210 Neb. Admin. Code ch. 45, § 006Aftermarket parts disclosureRead
New HampshireRSA 358-D:2, Regulation of Motor Vehicle Repair FacilitiesRepair statuteRead
New Mexico12.2.6 NMAC, Requirements for Repair of VehiclesRepair regulationRead
North CarolinaN.C.G.S. art. 15B, §§ 20-354.2 and 20-354.4Repair statuteRead
North DakotaN.D. Cent. Code § 39-05-17.2(4)Body damage disclosure dutyRead
OklahomaOkla. Stat. tit. 15, § 955Aftermarket crash parts disclosureRead
OregonORS 746.292(2)Repair statute, body and frame shopsRead
Pennsylvania37 Pa. Code § 301.5, Automotive Industry Trade PracticesRepair regulationCite only
South CarolinaS.C. Code Ann. § 39-5-20(a)General UDAP onlyRead
South DakotaSDCL § 58-33-71Aftermarket crash parts disclosureRead
TennesseeTenn. Comp. R. & Regs. 0780-01-59Aftermarket crash parts regulation, insurer-directedRead (as noticed)
TexasTex. Ins. Code § 1952.301, 28 TAC § 5.501Insurer duty, no shop-facing ruleRead
Vermont9 V.S.A. § 2453(a)General UDAP onlyRead
VirginiaVa. Code Ann. § 59.1-207.3, Automobile Repair Facilities ActRepair statuteRead
WashingtonRCW 46.71.025, ch. 46.71 Automotive RepairRepair statuteRead
West VirginiaW. Va. Code § 46A-6B-4Aftermarket crash parts disclosureRead
WisconsinWis. Admin. Code ATCP 132.02, Motor Vehicle RepairRepair regulationRead
WyomingWyo. Stat. Ann. §§ 40-12-101 to 40-12-114, Wyoming Consumer Protection ActGeneral UDAP onlyRead

Thirty-four of the thirty-six were read first-party. One is cite-only because a state wall stopped us at the operative text, and one is a lead we could not confirm at all. On 2026-08-20 that split moved twice in a day: 28 / 4 / 4 at the start, then 32 / 3 / 1, then 34 / 1 / 1. The six rows that moved are Alabama, Montana, Oklahoma, Wyoming, Alaska and Tennessee, and not one of them moved because a wall came down; each is described in the Corrections. The two that did not move are Pennsylvania (cite only) and Mississippi (lead), and the reason in each case is that no government host publishes the text at all, which is a different sentence from "we could not get in."

What the pattern shows. Roughly a dozen of these states have a genuine repair-transaction statute or regulation, with estimates, authorisation, parts disclosure and parts return. Another dozen or so reach the repair transaction only sideways, through an aftermarket crash parts disclosure rule aimed mostly at insurers. And four states have nothing repair-specific at all: Georgia, South Carolina, Vermont and Wyoming rely on their general deceptive trade practices act, which is why those rows are marked as such.

That is the answer to the question this whole page is really about. "Is the shop licensed?" is the wrong question in 36 states. "What does the law require the shop to tell me?" has an answer in every one of them, and it is in the table.

Three rows deserve a footnote. Kentucky's 806 KAR 12:095 is a repair regulation that binds the insurer, not the shop: we searched KRS ch. 367, ch. 190 and ch. 304 and found nothing shop-facing. Texas is the same shape, with Tex. Ins. Code § 1952.301 and 28 TAC § 5.501 both aimed at carriers, and the Texas DMV separately confirming the state does not license repair shops. Tennessee joined them on 2026-08-20 once we could read the chapter: 0780-01-59-.04(1) binds the insurer and .05 enforces through the Unfair Claim Settlement Practices Act. In all three, a consumer's leverage runs through the insurer.

What we are not saying

What to do with this

If you are checking one shop. Find the state on the table, then read that state's guide where one exists: each covers where the official record lives, what the status words mean, and what the register does not tell you.

If you are comparing shops across states, do not treat the credentials as equivalent. A California ARD number and an Ohio Motor Vehicle Repair Board registration are both "licensed" and are not comparable evidence.

If a shop is in one of the 36, ask for the things a register would have told you: manufacturer certifications, I-CAR or equivalent training, and written confirmation of the repair procedures they follow.

If you are doing this research yourself, read the salvage chapter's definitions section first. That is where two of the fourteen were hiding.

Does each citation point at a duty, or only at a definition?

A citation can be real, in the right chapter, first-party, current, and still not support the sentence attached to it. The commonest way that happens in a compilation is a pinpoint to the definitions section of an act, and not to the provision that actually imposes something. On 20 August 2026 we ran that test against every row in this table we are able to read first-party. That was 28 rows when the sweep started and 34 rows by the time it finished, because the sweep sent us back at the walls and six of them turned out to have a government door we had simply never tried. Five rows needed correcting, and the fifth is the one worth reading: it changed not the confidence label but who the duty binds.

Arizona was wrong, and it is the same failure as Connecticut. This page gave A.R.S. § 20-461(A)(15) and described it as the aftermarket parts notice. Paragraph (A)(15) is "Failing to promptly provide a reasonable explanation of the basis in the insurance policy ... for denial of a claim." That is a generic claim-denial duty. The aftermarket crash parts provision, with its written notice and its ten-point type requirement, is (A)(16). Right statute, right section, wrong paragraph. Corrected above.

Louisiana was not a duty at all. We cited R.S. 32:1254(A)(7). Read on its own, paragraph (7) is four words: "Satellite warranty and repair centers." It is an enumerated category, not a sentence that requires anything. The duty is in the subsection (A) chapeau: "The following persons shall be licensed by the commission in order to engage in business in the state of Louisiana ... and it is a violation of this Chapter to operate without first obtaining a license." The row now cites the chapeau and keeps (7) as the item that brings satellite centres inside it.

Connecticut, corrected earlier the same day: CGS 14-51 is headed Definitions; the licence duty is § 14-52(a).

North Carolina pinpointed § 20-354.2, which is Definitions. It was chosen deliberately, because that definition is what makes Article 15B reach paint and body shops, so this one was defensible where Arizona was not. The row now names § 20-354.4 beside it.

The other 30 all point at a duty. Spot-checking a few so the claim is testable: Wisconsin ATCP 132.02 is Repair authorization ("No shop may perform any repair that has not been authorized by the customer"); Washington RCW 46.71.025 is Written estimate required; West Virginia § 46A-6B-4 is Notices and written statements to be provided to vehicle owner; Minnesota § 325F.58 is the estimate duty inside the Truth in Repairs Act; New Mexico 12.2.6.10 NMAC frames each obligation as "It is an unfair or deceptive trade practice for an automotive repair facility to fail to ...". Of the six rows that moved into Read today, four are duties on the shop's face and two are duties on the insurer: Alabama § 32-17A-3 is headed Disclosure Document; Oklahoma § 955 reaches the shop directly, and the definitions sit one section earlier at § 953; Montana 23.19.202 opens "It shall be an unfair or deceptive act or practice for a motor vehicle repair business to"; Wyoming § 40-12-105 is headed Unlawful practices and is general commercial law, which is what that row already said; Alaska AS 45.45.130 is headed Repair order and runs a chain of shop duties through AS 45.45.220, with the definitions parked at the end in AS 45.45.240. Tennessee is the second insurer duty and is discussed below, because it changed what the row says, leaving our confidence in it untouched.

Where the ranges land. Seven rows cite a range, and in every one of them the opening sections are the definitional part and the duty sits further in: Colorado § 42-9-101 is a short title and § 42-9-102 definitions, with the consent and estimate duty at § 42-9-104; Delaware § 4901A is purpose and § 4902A definitions, with unlawful practices at § 4903A; Georgia's core prohibition is § 10-1-393; Minnesota's is § 325F.58. Citing the range is correct for the question this column answers, which is which law governs the transaction, but a reader who wants the duty should go to those sections.

Four of these govern the insurer, not the shop, and the table says so in its own column: Kentucky 806 KAR 12:095 § 8, Arizona § 20-461, Texas Ins. Code § 1952.301 with 28 TAC § 5.501, and Tennessee 0780-01-59. If you are looking for what the law requires of a body shop, those four do not answer it. They answer the converse.

Tennessee was the fourth, and it was this page that had it wrong. Until 2026-08-20 the row read "aftermarket crash parts regulation" with no note about who it binds, and this paragraph said three. Reading the chapter settled it: .04(1) opens "No insurer shall specify directly or indirectly the use of non-OEM aftermarket crash parts," and .05 enforces the whole chapter through the Unfair Claim Settlement Practices Act at Tenn. Code Ann. § 56-8-104(8). One subsection, .04(2), is written in the passive: "Non-OEM aftermarket crash parts shall not be used on current year model or immediate prior year model motor vehicles without the express written permission of the insured." It names no actor, so a shop could read itself into it. The enforcement section is what decides it. This is the same lesson as Arizona and Louisiana arriving by a different road: reading the text changed the characterisation, not the confidence label, and a compilation that only ever checks confidence would never have caught it.

What we still cannot test, and why. Two rows are marked Cite only or Lead because no government host publishes their operative text, so the duty-versus-definition test cannot be run on them first-party: Mississippi (Lead) and Pennsylvania (Cite only). It was eight rows at the start of the day. The six that moved are described in the Corrections; the two that did not are described below, and in both the obstacle is an absent publication. We are not going to run the test on a mirror and call it done.

A sourcing weakness this sweep exposed, and then closed the same day. We had recorded that Arkansas and Colorado publish no statutory text on any government server. Both delegate their official code to LexisNexis, whose portal returns 403 to an automated reader, so every citation to those two codes rested on a labelled commercial mirror, and not on a state host. That is no longer true, and the route is worth naming because it generalises: a state that hides its code still publishes its acts. Arkansas's General Assembly serves the enacted text of Act 1209 of 1991 and Act 835 of 1997 as PDFs on its own server. Colorado's Office of Legislative Legal Services serves the 1997 session law that wrote the consent-and-estimate duty into the Motor Vehicle Repair Act. Both are quoted in the Sources. Every Read row on this page is now read on a government host, with one stated exception that is described in the Montana source entry, in the open.

What we could not verify

Corrections

2026-08-20, seventh pass: two more doors, and the text corrected a row rather than a label. The sixth pass left four rows unread and called them walls. Two of the four were never walls at all, and finding that out changed one row's meaning, not just its confidence.

Alaska was Cite only because akleg.gov answers a fetcher with 403 on every statute-text path. It answers a browser with the whole of Title 45, chapter 45, under the heading Alaska Statutes 2025. The Automobile Repair Act runs AS 45.45.130 to 45.45.240 and is a chain of duties on the shop: Repair order, Repair price information, Notice to customer, Authorization to proceed with repairs, Return of parts, Invoice, Prohibited practices, Records. AS 45.45.130 opens "Upon request of the customer and before the commencement of repairs, the shop shall provide the customer with a copy of a dated repair order." Two things worth keeping. The definitions sit at the end, in AS 45.45.240, not the beginning, so the usual definitions trap does not apply here. And AS 45.45.210 requires every shop to print "Motor vehicle repair trade practices are regulated by Alaska Statutes 45.45.130 to 45.45.240" on its invoices, which means the statute confirms the range this table prints, the same self-confirmation Wyoming gave. The 45.45.185 trap this page warned about two passes ago is also now settled rather than suspected: that section appears nowhere in the statute index, so the bill it came from did not become law. Read.

Tennessee was Cite only because the Secretary of State's rules host returns 403 on chapter files, which is still true and was control-tested. But the Department of Commerce and Insurance publishes its own rulemaking hearing file, at 200, on tn.gov, carrying the whole of chapter 0780-1-59 as substituted, with the Secretary of State's RECEIVED stamp of 27 April 2004 on the last page. It is an image scan with no text layer, which is a parsing problem and not a refusal, so we read the three pages by eye. Read, marked as noticed, because what we read is the text as filed in the rulemaking that was adopted rather than a consolidated current copy, and that limit belongs on the row.

And reading it corrected the row. See the duty-versus-definition section above: chapter 0780-1-59 binds the insurer, and this page had it filed as an unqualified aftermarket crash parts regulation and had told you that only Kentucky and Texas regulate the insurer and never the shop. That count was wrong. It is three. This is the first correction on this page that a confidence audit could never have produced, because the citation was right, the tier was honestly stated, and the sentence beside it was still wrong.

Pennsylvania and Mississippi did not move, and the reason is now specific rather than general. Pennsylvania is not a locked door: chapter 301 was promulgated in 1978 and the Independent Regulatory Review Commission, the first-party route to a Pennsylvania rule's text, was created by Act 181 of 1982. We enumerated the whole of IRRC docket #3373, including the two scanned trade-association letters that had been the honest gap, reading both by eye. Every document prints §§ 301.1, 301.2 and 301.4 and none prints § 301.5. Mississippi is unchanged and now better tested: the Insurance Department's consumer page describes the chapter's parts rules without citing a section, and a 2021 Senate bill that looked promising turned out to concern the Motor Vehicle Commission law instead.

2026-08-20, sixth pass: eight walls, and four of them had a door. This page had just finished telling you that eight rows could not be duty-tested because a wall stopped us, and that Arkansas and Colorado rested on commercial mirrors. Six of those ten are first-party now, and not one of them moved because a wall came down. They moved because we had only ever tried one door on each.

Alabama was a Lead because ALISON serves no statutory text to a plain reader. It serves text to a browser, which is a different sentence, and § 32-17A-3 is headed Disclosure Document: "the written estimate prepared by the insurer and repair facility shall clearly identify each such part." Read.

Oklahoma was Cite only because the Supreme Court Network disallows automated reading and so does oklegislature.gov. The State Senate publishes the whole of Title 15 as a PDF and blocks nothing at all. § 955 puts the duty on the shop in terms: "nor shall a repair facility or installer use non-original equipment manufacturer aftermarket crash parts to repair a vehicle, unless the consumer is advised in writing." Read. And worth noticing that § 953, one section earlier, is the definitions section, which is the exact trap this sweep exists to catch.

Wyoming was Cite only for the same reason and had the same answer: the Legislature publishes Title 40 as a PDF. § 40-12-101 names the act and § 40-12-102(a)(x) defines "this act" as W.S. 40-12-101 through 40-12-114, which self-confirms the range this table prints. We also stopped asserting the "general UDAP only" label on that row and started testing it. Across those fourteen sections the words vehicle, automobile, body shop, repair shop, crash part and collision appear zero times, while merchandise appears 35 times and deceptive 21. The second count is the control that makes the first one mean something rather than being a failed search.

Montana was a Lead because rules.mt.gov answers an automated reader with a human-verification page, and it still does. But the Judicial Branch law library hosts the Montana Administrative Register back into the 1990s, and the Register is where a rule's text is printed when it is adopted. Rule 8.78.202, since renumbered 23.19.202, is headed Repairs, estimates and invoices and opens "It shall be an unfair or deceptive act or practice for a motor vehicle repair business to". This row is marked Read with a limit that belongs in the open: what we read is the 1996 amendment under the predecessor number, the enumerated subsections beneath that opening line are carried by reference rather than reprinted, and the current consolidated text remains behind the check. That is more than a Lead and less than the other thirty-one, and the row and the source entry both say so.

Mississippi and Pennsylvania did not move the same way, and we are not going to pretend they did. Mississippi stays a Lead. The code is Lexis-published, § 63-27-5 was enacted in 1990, and the Legislature's bill archive begins in 1997, so the act that wrote it is on no state server at all. A 2006 bill on that server refers to "the provision expressed in Section 63-27-5", which proves the section exists and reveals nothing about what it says, so it does not earn Cite only. Pennsylvania moves from Lead to Cite only, which is a smaller step than it sounds. All three Pa. Code and Bulletin hosts disallow automated reading and § 301.5's text is not obtainable. What is first-party is the Independent Regulatory Review Commission's own final-form package for Chapter 301, which confirms the chapter is the Attorney General's Automotive Industry Trade Practices and prints §§ 301.1, 301.2 and 301.4, but not 301.5. We considered citing § 301.2 instead, since it is first-party and it does reach "maintenance service or repair on a new or used motor vehicle." We did not. § 301.5 is the repair-shop section and § 301.2 is the advertising section, and swapping the citation to earn a better confidence label would be the precise failure this page recorded two passes ago.

Tennessee and Alaska stayed Cite only at the end of the sixth pass, and both moved in the seventh, which is recorded above. What we wrote here at the time is worth preserving because it was true of the hosts we had tried: Tennessee's Secretary of State serves the chapter index and returns 403 on the chapter file, with a neighbouring chapter requested as a control returning 403 as well, so it is that host refusing rather than a bad filename. Alaska's legislature returns 403 on every statute-text path we had used. Both statements are still accurate. Both were also the wrong question, because in each state a second publisher was serving the same text in the open.

2026-08-20, fifth pass: Arizona pointed at the wrong paragraph, and Louisiana at no duty at all. We ran the duty-versus-definition test against all 28 rows in the governing-law table that we can read first-party, rather than the six of the fourth pass. Two more failures. Arizona was given as A.R.S. § 20-461(A)(15) and described as the aftermarket parts notice; (A)(15) is the generic claim-denial duty and the aftermarket provision is (A)(16). Louisiana was given as R.S. 32:1254(A)(7), which on its own is the four-word category name "Satellite warranty and repair centers" and imposes nothing; the duty is the subsection (A) chapeau. Both corrected above. The lesson is the one this page keeps learning: a citation can be real, first-party and current and still be attached to the wrong sentence, and the only way to find out is to read what the cited provision actually says rather than trusting the note beside it.

2026-08-20, also fifth pass: New Jersey is first-party now. It was mirror-sourced, and this page said so. The Legislature publishes no codified statutory text a reader can reach, but it does publish the enacted session law on its own server, and P.L.2001, c.53, s.2 carries this section under the heading C.39:13-2. The amendment chain accounts for the only difference from current text. All fourteen licensed states are now read on a government host.

2026-08-20, fourth pass: every one of the fourteen now carries a section, and one of them pointed at the wrong section. This page told you fourteen states license a repair shop and gave an authority for each. Five of those authorities were not pinpoints. Massachusetts was a bare chapter, Michigan was an act with an et seq., New Jersey and Ohio were bare chapters, and Rhode Island cited a chapter and a rule but no statutory section. All five now carry the operative provision, read first-party except New Jersey, which is marked cite-only above.

Connecticut was worse than imprecise. It was wrong. The authority given was CGS 14-51, which is headed Definitions. The provision that actually requires the licence is § 14-52(a). The old citation was real, in the right chapter, and about the wrong thing, which is the failure this site has now recorded often enough to name: a citation can be genuine and still not support the sentence it is attached to. It is corrected above and the definitions section is kept where it belongs, as the definitions section.

Five of the fourteen also had no entry in the Sources list at all while the page said every claim was sourced: Connecticut, Florida, Massachusetts, New Jersey and Ohio. They are there now. The gap survived three previous passes because every pass checked the count of jurisdictions and none checked whether each named state had a source line.

2026-08-19, third pass: thirteen is fourteen. Missouri. We had run a first-party sweep of all 51 jurisdictions the same day and it did not surface RSMo § 301.218, because the sweep looked where body-shop regulation belongs. A second pass that ran keyword searches first and then confirmed hits first-party found it immediately. The lesson is the order of operations: search engines index the pages a state writes for shop owners, and those pages name the credential in the words an owner would use. Reading the code first and searching second is how you miss a licence filed under scrap processors.

2026-08-19, second pass: twelve is thirteen. Illinois, described in full above. Yesterday's page had already published Illinois as its open question, with a note saying we could not resolve the definition, and then left it there for a day. The caution was right. Publishing a doubt is not the same as discharging it.

2026-08-18: nine is twelve. Hawaii, Michigan and Utah. Hawaii was the bad one, because we already knew: our own guide on aftermarket parts and glass describes HRS 437B as "a repair-licensing statute; it sits under consumer affairs, it binds the shop rather than the insurer." Two pages on this site disagreed about the same chapter for as long as both existed. Michigan's sits in a 1974 act administered by the Secretary of State. Utah's appears as item (l) in a list of twelve licence classes that is otherwise about dealers, crushers and dismantlers. All three were found because a checker reported that this page named 9 of 51 jurisdictions, and filling the gap meant looking up all 41 rather than accepting the number.

Three corrections, all in the same direction, in two days. The negative list has gone 41, 38, 37, 36. That is the argument for naming it state by state rather than printing a number, and it is why the next miss should be findable by a stranger.

Sources

Governing-law sources for the 36, added 2026-08-20 when six walled rows and two mirror-sourced rows were taken first-party.

General consumer information: not legal, insurance, or financial advice. Requirements, coverage, and practices vary by state, policy, and manufacturer.

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Where this fits

Each link says what it is for. We add one only when a reader on this page has a real reason to need that page next.