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Progressive: What the Company's Own Repair Standards Require

Short answer: Progressive's published vendor standards require network shops to give it service equal to or better than any other carrier, and to get written consent before fitting a cheaper part than the estimate specifies. On cars, Progressive says it offers no OEM parts coverage.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-09-01 · 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

Progressive publishes the standards its network body shops must meet, written as contract terms, and one clause outranks every other. It is not an allegation or a leaked document. It sits on Progressive's own website, in the vendor conduct section, where anyone can read it.

The clause no other carrier may outrank

Progressive's published service and repair standards say:

"The Contractor and each Repair Facility will provide Progressive and/or its Claimants with a level of service (in terms of scheduling priority, cycle time and quality) that is equal to or exceeds the level of service that is provided to any other insurance carrier(s) by the Repair Facility."

That is the clause in full, including its subject. Read it slowly. The obligation is comparative, not absolute. The shop does not simply promise good service; it promises service at least equal to the best it gives anyone else, measured on scheduling priority, cycle time and quality.

For a shop that runs a mixed book, this is the most consequential sentence it will sign. Scheduling priority is a finite resource. The clause sets a floor, not a ceiling: a shop can comply by treating every carrier identically, but it cannot let any other carrier's work go ahead of Progressive's on scheduling priority, cycle time or quality. The shop's own direct-pay customers are not an insurance carrier, and fall outside the comparison entirely.

The same page sets the operating cadence. A network shop must "Login to and check WebTracker at least four times throughout the day," and a supplement request "should be entered as soon as possible, not to exceed 48 hours of At Shop." The shop must also "maintain and provide a quality assurance program at each Repair Facility, subject to Progressive's reasonable approval" (repair standards). The shop writes the quality program; the carrier approves it.

The parts clause, read precisely

The parts language is easy to read as Progressive forcing aftermarket parts onto network shops. That is not what the published standard says, and getting it right matters.

The clause is conditional. It triggers when the estimate "Specifies an original equipment manufactured (OEM) part and Contractor desires to substitute a non-OEM part," or when the estimate "States that a part should be replaced and Contractor desires to repair the existing part instead." In either case the Contractor "Will notify Progressive" and "Will NOT substitute such non-OEM part or repair, rather than replace, the existing part, without Progressive's prior written consent" (repair standards).

Both triggers run downward. The shop needs written permission to fit a cheaper part than the estimate calls for, and written permission to repair a panel the estimate says to replace. On its face this is a control against a shop pocketing the difference between what was authorized and what was fitted. It protects the vehicle owner as much as the carrier, and any fair account has to say so.

What the published standards do not contain is the mirror image. There is no published clause on that page addressing a shop that wants to fit an OEM part where the estimate specifies aftermarket, and no published clause requiring Progressive's written consent to move in that direction. The document governs deviation below the estimate. The estimate itself is written elsewhere.

Where it is written matters, because Progressive states its parts position plainly on its consumer site:

"Insurance companies write estimates that include aftermarket parts for repairs because they can return a vehicle to pre-loss condition and usually cost less than OEM parts."

"At Progressive, OEM parts coverage is offered for motorcycles but not for cars."

"If you or your shop of choice use OEM parts when aftermarket parts are available to repair the vehicle to pre-loss condition, you may have to pay the difference in cost between the aftermarket and OEM part."

All three sentences are published by Progressive on its aftermarket parts page. Read them precisely: the first describes what "insurance companies" do, not what Progressive alone does; the second and third are about Progressive by name. Put beside the vendor standards, the structure is complete without needing a single allegation: Progressive's published explanation of why estimates include aftermarket parts, no OEM parts coverage sold on cars, and a stated possibility that the vehicle owner pays the OEM-to-aftermarket price difference. The network shop separately owes a restoration duty: "The Contractor is obligated to complete all repairs that are necessary to restore the vehicle to its Pre-loss Condition" (repair standards).

That is a real tension, stated without embellishment. The shop carries the obligation to restore pre-loss condition and needs written consent to deviate downward from the estimate, while on cars Progressive sells no coverage for OEM parts where aftermarket parts are available. We do not claim that these documents show how that tension resolves on any given repair order; they do not answer it, and neither does this page.

One further term shapes the commercial risk. On network referrals, "The Contractor is responsible for collecting the full cost of repairs from the vehicle owner." Progressive is not absent from that transaction, and the next sentence on the same page says why: "Generally, payments made by Progressive will be issued jointly to the Contractor and the vehicle owner," and Progressive "reserves the right to issue payment to the vehicle owner and his/her lien holder" (Progressive repair authorization standards). The money is Progressive's. Getting it out of a jointly payable draft and into the shop's account is the shop's job.

And the network carries a benefit an independent shop cannot match. Progressive's limited lifetime guarantee is network-only: "If you choose one of our network shops, you receive a lifetime guarantee on the covered repair for as long as you own or lease your vehicle." It "also doesn't apply to any work on the covered repair performed by anyone outside Progressive's network. Any such work voids the guarantee," and "it isn't transferable and is no longer valid if you sell or transfer your vehicle" (Progressive lifetime guarantee).

That network is now the company's repair infrastructure. In January 2018 Progressive announced that its "68 Service Centers will stop being a drop-off/pick-up point for customer vehicles," with most remaining as regional claims offices and customers directed to "nearly 3,000 Progressive approved shops" (Progressive news release, 2018-01-11). Its FY2025 Form 10-K says its claims employees are "supported by centralized functions at our corporate offices and a nationwide network of about 4,700 third-party repair shops" (FY2025 10-K). Progressive stopped taking custody of vehicles and grew the contractual network by more than half instead: nearly 3,000 shops in 2018, about 4,700 in the 2025 filing. Nothing in these documents obliges a customer to use the network, and Progressive's own parts page refers to "your shop of choice." What the network changes is the terms on which the work is done.

The total-loss valuation fight

The second body of public record concerns totaled cars rather than repaired ones, and it is large.

Across the cases in this record, Progressive's total-loss valuations come from Mitchell International, and a federal court has described the mechanism. Mitchell's reports apply a Projected Sold Adjustment that reduces the listed price of a comparable vehicle. It is not applied to every comparable. Per the Seventh Circuit: "These adjustments apply when only a list price is available for a comparable car and the car is not listed at a known 'no haggle' dealer." The same court set out how the adjustment is built: J.D. Power "estimates sold prices as a function of list prices for different make, model, year, and market area combinations" (Schroeder v. Progressive Paloverde Ins. Co., No. 24-1559, 7th Cir., 2025-07-24).

Then comes the sentence that defines the dispute, quoted whole: "Projected Sold Adjustments never project that a car will sell for more than its list price, and until mid-2021, they projected that every car would sell for less than its list price" (same opinion).

A correction that can only ever reduce is not a correction in the ordinary sense. That asymmetry is the court's own description of the mechanism, not a plaintiff's characterization, and it is what the litigation below is about.

Progressive's side of it is on the record too, and belongs here. The Ninth Circuit recorded Progressive's rationale that the adjustments "reflect consumer purchasing behavior (negotiating a different price than the listed price)." The dissent in the same case recorded that the method later changed: "After July 2021, Projected Sold Adjustment ('PSA') continued to be calculated using transactions where the sold price was less than the listed price, but it added into the calculation transactions where the sold price was equal to the listed price" (Ambrosio v. Progressive Preferred Ins. Co., No. 24-2708, 9th Cir., 2025-09-12). The one-way property the Seventh Circuit described is therefore narrower after mid-2021 than before it.

The scale is unusual, and both sides say so. In a joint stipulation filed in Nevada federal court and granted by the magistrate judge on 2023-12-06, the plaintiffs and Progressive's own counsel told the court that "This case is one of 35 related class actions [against] Progressive and its affiliates challenging the calculation of the Projected Sold Adjustment ('PSA') in valuing total-loss claims (the 'PSA Cases')," and that one firm, King & Spalding, "represents the defendants in all the PSA Cases" (Yaghyazarian v. Progressive Direct Ins. Co., No. 2:22-cv-01339, D. Nev., 2023-12-06). The bracketed word is an editorial insertion; the filed sentence omits it. This is the parties' joint description of the docket, not a judicial finding. That makes it stronger, not weaker, since Progressive's lawyers signed it.

The methodology itself is not public. In a Kentucky case a court granted a motion brought by third-party subpoena respondents to seal deposition exhibits reflecting "proprietary data and methodology for the Projected Sold Adjustment" and "features of Mitchell's proprietary WorkCenter Total Loss software, proprietary business information, and trade secrets." The same order records that "J.D. Power contracts with Mitchell to provide data and statistical methodology for the Projected Sold Adjustment" (Watson v. Progressive Direct Ins. Co., No. 5:22-cv-00203, E.D. Ky., 2024-03-04). The seal was sought by the vendors, not by Progressive. The number that reduces a consumer's settlement is produced by a method whose description a court has sealed as a trade secret.

One outcome is settled and verifiable. In New York the order provides that "Defendants shall create a common fund of $48,000,000 (the 'Settlement Fund') for the benefit of the Settlement Classes." The lead defendant is Progressive Casualty Insurance Company. The court gave final approval on 2025-03-06, finding the settlement "fair, reasonable, and adequate and in the best interests of the Settlement Class Members," and recorded that "No Settlement Class Member objected to the Settlement, and only five Settlement Class Members have opted out" (Volino v. Progressive Casualty Ins. Co., No. 1:21-cv-06243, S.D.N.Y., final approval order).

Settlement is not liability, and the order says so in terms. It provides that neither the agreement nor the settlement "is or shall be construed as, an admission of, or evidence of, the truth of any allegation or of any liability or the validity of any claim" (same order). Progressive funded $48 million and admitted nothing. Both halves are true. We are not claiming that the settlement establishes that any valuation was wrong; the order forecloses that reading, and this page follows the order.

What the appellate wins actually decided

Progressive has won real victories in this wave, and they deserve to be reported as wins.

In the Seventh Circuit, Progressive got class certification reversed outright. The panel, with Judge St. Eve writing, concluded: "We therefore REVERSE the district court's class certification order and REMAND for further proceedings consistent with this opinion." It held that Progressive's use of the adjustment "does not by itself establish liability for breach," and on predominance it reasoned: "Even if a jury found that cars always sell for their list prices, this finding would not establish that Progressive underpaid each putative class member" (Schroeder, 7th Cir., 2025-07-24).

In the Ninth Circuit, Progressive successfully defended a denial of certification. The panel affirmed, concluding that "it cannot be said that common issues 'predominate over any questions affecting only individual members'" (Ambrosio v. Progressive Preferred Ins. Co., No. 24-2708, 9th Cir., 2025-09-12).

Now the half that usually goes missing, and it runs in both directions.

Both dispositions are Rule 23 rulings about whether injury can be proved on a classwide basis. The Seventh Circuit reversed certification and remanded for further proceedings, which is not a dismissal; the individual claims survive. The Ninth Circuit was reviewing a denial of certification, not the merits of the adjustment. Neither court found that any particular valuation was accurate or that any insured was paid what the policy owed. Anyone describing these outcomes as Progressive being cleared of the valuation claims is misreading them.

The other direction is the strongest thing in this record for Progressive, and it should not be buried. Along the way the Seventh Circuit decided a contract question on the merits: "We conclude that the policy does not preclude Progressive from applying Projected Sold Adjustments in calculating its settlement offers, so long as Progressive ultimately pays its insureds the actual cash value of their totaled cars as defined in the policy and by Indiana law" (Schroeder). On that policy, under Indiana law, using the adjustment is not itself a breach. What the court left open is whether the resulting payment equals actual cash value, and that is the question it sent back.

The Ninth Circuit decision also drew a dissent. Judge Wallach wrote that "The PSA deductions are all downward adjustments to the Mitchell Value, even though the PSA deductions may vary across individuals," argued that "the majority adds to an intra-circuit split that can only be resolved by the Ninth Circuit taking this case en banc," and said plainly that "this case would be a good choice for en banc review" (Ambrosio dissent). The law here is unsettled, and a judge on the winning panel said so.

Snapshot, and why it is crash evidence

The least discussed item in Progressive's public documents is the one most likely to turn up in a repair dispute.

Snapshot is marketed as a usage-based discount program. "Snapshot collects information about how you drive, how much you drive, and when you drive" (Snapshot FAQ). The plug-in device "records vehicle speed and time of day, when the device is plugged in and unplugged from the vehicle, the Vehicle Identification Number, and may record G-force and vehicle location using GPS" (Snapshot privacy statement, last updated 2020-07-13).

Speed, G-force, GPS position, time of day, tied to a specific VIN. Those are rating inputs, and Progressive says so. They are also, taken together, a description of a collision.

Three further terms matter. Progressive states: "We will retain this data indefinitely." It says it will disclose the data "When we determine that we're legally required to provide the data, such as in response to a subpoena in a civil lawsuit or by police when investigating the cause of an accident." And it uses the data "To assist in resolving insurance claims, including sharing data in litigation or with other insurers for subrogation purposes involving the claim" (Snapshot privacy statement).

The program is also not purely a discount. On location, Progressive says: "While location data is collected as well, it doesn't impact the Snapshot results you earn, but may be used for underwriting purposes." And on price, "riskier driving based on these factors indicate a greater likelihood of being in an accident and may result in a higher rate at renewal," which Progressive qualifies by state and by when the customer enrolled (Snapshot FAQ).

Why a collision shop should care: impact severity is frequently the pivot in a disagreement about repair scope. Whether a carrier accepts a suspension component, a sensor, or a structural operation as accident-related often turns on how hard the vehicle was hit. Progressive's own terms describe indefinitely retained G-force and speed data, attached to a VIN, expressly available in litigation and subrogation. We are not saying that Progressive has used Snapshot data to contest repair scope: no source we located establishes that it has, and we report only what the terms permit.

Where the record runs the other way

Two findings cut against the picture above, and they are as well sourced as anything in it.

Delaware examined Progressive Direct's personal auto claims handling for the period 2018-01-01 through 2020-06-30 and found 13 exceptions in total (Delaware market conduct examination report). Four were cited under Delaware's prohibited unfair claim settlement practices rule, and in three of those "the Company did not appropriately settle the original claim and after review by the examiner, additional funds were remitted to the policyholder." Five training recommendations were issued; no penalty was specified.

The total-loss result is the one that matters here. The report records that "The examiners were provided a total universe of 2,605 total losses during the exam period" of 2018-01-01 through 2020-06-30, that "A random sampling of 108 claims was selected in accordance with the NAIC Market Regulation Handbook guidelines," that "Special emphasis was placed on how a total loss valuation was determined," and then: "No exceptions were noted" (Delaware market conduct examination report). Zero exceptions in 108 total-loss files is a genuine counterweight to the litigation above, and it is stated here deliberately. Its scope should be understood too: a state exam tests compliance with that state's claims-handling rules, which is a different question from whether a valuation methodology understates actual cash value.

Second, on political influence. A query of the U.S. Senate Lobbying Disclosure Act database for clients named "progressive" in 2025 returns 16 filings, and none of them is The Progressive Corporation or any Progressive insurance entity. The matches are unrelated organisations, including Progressive Expert Consulting and Protecting Progressive Values (U.S. Senate LDA filings API). Progressive filed no federal lobbying disclosures under its own name in 2025. That finding should be scoped precisely: it concerns federal LDA filings under the company's own name, and says nothing about state-level activity or about trade association spending.

The steering allegations, stated as allegations

In 2020 the Eleventh Circuit decided a consolidated appeal (Nos. 16-13596, 16-13601 and 16-15467) arising from the body shop antitrust litigation. On the antitrust claims the shops lost on the merits of their pleading: "Allegations of parallel conduct, even conscious parallelism, are insufficient standing alone to raise an inference of conspiracy" (Automotive Alignment & Body Service, Inc. v. State Farm Mut. Auto. Ins. Co., 11th Cir., 2020-03-06).

Two claims against Progressive survived. Per the opinion, "AutoWorks Collision Specialist and Walkers Collision Center allege that they each lost one customer because Progressive misleadingly told the customers that it would guarantee the repair work if they used Progressive's preferred shops, but not if they used Autoworks or Walkers." The court held: "We agree with the body shops that AutoWorks and Walkers have plausibly alleged that Progressive intentionally damaged their businesses with the malicious intent to injure them and without right or justifiable cause" (same opinion).

Read that with care. "Plausibly alleged" is the language of a pleading standard. These are allegations that cleared a motion to dismiss in 2020. We are not saying that Progressive did these things: they are not findings that it did, no final judgment on them was located, and what happened on remand is unknown.

The factual backdrop is worth naming, because it is undisputed: Progressive's guarantee genuinely is network-only, and outside work genuinely does void it, as the company's own page says. The contested question was never whether that is true. It was how it was presented to a customer choosing a shop.

What we could not establish

Every other source cited on this page returned its document on request. No login gate, paywall, robots disallow or scripted-request refusal was encountered on the sources listed below.

Corrections

This page is new, and the entries below are corrections made to its own draft before publication, not after. A page that shows only its wins is not evidence of anything, so the errors the fact-check caught are logged here with the same dates and detail an after-publication correction would get.

2026-09-01, appellate merits holding. The draft said the courts of appeals had decided nothing on the merits, in the words "neither holds that the Projected Sold Adjustment is lawful, accurate, or permissible." That was false, and it was false in Progressive's favour. The Seventh Circuit did reach a merits question: "We conclude that the policy does not preclude Progressive from applying Projected Sold Adjustments in calculating its settlement offers, so long as Progressive ultimately pays its insureds the actual cash value of their totaled cars as defined in the policy and by Indiana law." That holding now has its own paragraph in the appellate section, and the Rule 23 framing has been narrowed to what the courts did not find.

2026-09-01, the "35 related class actions" attribution. The draft attributed the count of 35 related PSA class actions to a federal court in Nevada, as though it were a judicial finding. The docket entry as read on 2026-09-01 shows the sentence sits in the parties' joint stipulation for an extension of time, which the magistrate judge granted. It is now attributed to the joint stipulation, with the accompanying fact that one firm represents the defendants in all of them, and the bracketed word marked as an editorial insertion. The statement is not weaker for the correction; Progressive's own counsel signed it.

2026-09-01, how broadly the adjustment applies. The draft said the Projected Sold Adjustment reduces the advertised price of each comparable vehicle. The Seventh Circuit says it is conditional: "These adjustments apply when only a list price is available for a comparable car and the car is not listed at a known 'no haggle' dealer." The condition is now quoted and the universal claim is gone.

2026-09-01, Snapshot data described as not a rating input. The draft said of speed, G-force, GPS position and time of day that "That is not a rating input. That is a description of a collision." The first half was wrong: speed and time of day are expressly Snapshot rating factors on Progressive's own page. The sentence now says both true things, that they are rating inputs and that together they describe a collision.

2026-09-01, who pays the repair bill. The draft quoted the vendor standard putting collection on the shop and glossed it as collection risk sitting with the shop and not the carrier, which implied Progressive does not fund the repair. The next sentence on the same page, omitted from the draft, says payments "will be issued jointly to the Contractor and the vehicle owner." It has been restored alongside the lien-holder sentence.

2026-09-01, who sealed the methodology. The draft reported the Kentucky sealing order without naming the movant, which left the impression that Progressive sealed its own valuation method. The motion was brought by the third-party subpoena respondents, the vendors, and the section now says so and describes only what the court actually sealed.

Related

Sources

Each source above was read on 2026-09-01, and every quotation on this page was re-pulled from its primary source and string matched against it before publication. Anything that would not re-verify was cut rather than softened, which is why several widely repeated figures and steering details appear in the section above as absences instead of as claims. This page reports what public documents say; it is not legal advice, and a shop or vehicle owner with a live dispute should take advice on their own facts.

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

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