New York, California and Connecticut Ban Steering, and No Two of Them Ban the Same Thing

Short answer: "anti-steering law" is a category, not a rule. Three states we read first-party have one, and no two work the same way. The machinery differs in every case:

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-08-21 · 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

• New York bars requiring and bars recommending, and the only thing that unlocks recommending is the insured asking for it.
• California bars requiring and bars recommending, but a written notice of your right to choose unlocks recommending, and if you accept the recommendation the insurer takes on an obligation.
• Connecticut bars requiring and does not bar recommending at all. Instead it bans one specific sentence, and it binds the appraiser as well as the insurer.

They also disagree about glass, and about what size type the notice has to be printed in.

If you only remember one thing: a written notice means opposite things in New York and California. In New York it is a mandatory disclosure that changes nothing about what the insurer may say next. In California it is the permission slip that lets the insurer start recommending.

This page is a close read of three statutes, not a survey. A flat prohibition of the kind these three carry is unusual: most states let the insurer point you at a shop and then attach a duty to having pointed. If you want your own state rather than these three, we have since read all 51 jurisdictions and the answer is in what your insurer owes you if it picks the shop. Come back here for how the strictest three actually work.

New York: no recommending unless you ask

N.Y. Ins. Law § 2610(a): "no insurer providing collision or comprehensive coverage therefor shall require that repairs be made to such vehicle in a particular place or shop or by a particular concern."

§ 2610(b): "In processing any such claim (other than a claim solely involving window glass), the insurer shall not, unless expressly requested by the insured, recommend or suggest repairs be made to such vehicle in a particular place or shop or by a particular concern."

Read the exception. The only thing that lifts the bar on recommending is the insured expressly requesting it. There is no notice the insurer can hand you that unlocks it, no disclosure that buys the right, no script. Until you ask, the subject is closed.

§ 2610(c) then requires the insurer to give the insured a copy of its repair estimate carrying this disclosure, "plainly printed in no less than 12 point type":

"PURSUANT TO SECTION 2610 OF THE INSURANCE LAW, AN INSURANCE COMPANY CANNOT REQUIRE THAT REPAIRS BE MADE TO A MOTOR VEHICLE IN A PARTICULAR PLACE OR REPAIR SHOP. YOU HAVE THE RIGHT TO HAVE YOUR VEHICLE REPAIRED IN THE SHOP OF YOUR CHOICE"

Notice what that text does and does not say. It tells you the insurer cannot require. It does not mention the separate and stronger rule in (b) that the insurer cannot even suggest. The mandated notice under-describes the protection it is announcing.

And glass is carved out. Both (b) and (c) open with "other than a claim solely involving window glass". On a glass-only claim in New York, the recommending bar and the notice duty do not apply.

The New York bar was challenged for six years, and it held

This page shipped without the rest of the New York story, which is a real gap: anyone quoting § 2610(b) is quoting a section that spent three years unenforced, and an insurer's counsel will know that even if the shop does not.

Allstate and GEICO sued the Superintendent in the Southern District of New York in 1997, arguing that the bar on recommending was an unconstitutional restriction on commercial speech. On 5 May 2000 Judge Richard Conway Casey agreed as applied to them, and the Insurance Department told every motor vehicle physical damage insurer in the state, in Circular Letter No. 16 (2000), that they were "now free to recommend or suggest that repairs to a damaged vehicle be made in particular places or repair shops regardless of whether the insured expressly requested such recommendations."

Then it turned around. The Second Circuit declined to decide the constitutional question and certified four questions of state-law interpretation to the New York Court of Appeals. That court, in Allstate Insurance Co. v. Serio, 98 N.Y.2d 198 (2002), invalidated the Department's own 1994 reading of the section, the one contained in Circular Letter No. 4 (1994). On remand the District Court vacated its earlier order and dismissed the claims as moot, holding that the Court of Appeals decision and the Department's withdrawal of the 1994 letter had overtaken them.

On 4 December 2003 the Department withdrew Circular Letter No. 16 and issued Circular Letter No. 14 (2003), which has never been withdrawn and states plainly that § 2610(b) "remains in effect, and will be enforced by the Insurance Department consistent with the interpretation of the statute by the New York Court of Appeals."

Two things follow. The bar on recommending is live and enforced, not a dead letter. And it is enforced as the Court of Appeals read it rather than as the Department read it in 1994, so anyone arguing about the edges of what counts as a recommendation is arguing about that 2002 decision, not about the bare text.

California: the written notice is what unlocks recommending

Cal. Ins. Code § 758.5(a): "No insurer shall require that an automobile be repaired at a specific automotive repair dealer, as defined in Section 9880.1 of the Business and Professions Code."

So far, the same as New York. Then it diverges.

§ 758.5(b)(1): "No insurer shall suggest or recommend that an automobile be repaired at a specific automotive repair dealer unless either of the following applies: (A) A referral is expressly requested by the claimant. (B) The claimant has been informed in writing of the right to select the automotive repair dealer."

Two unlocks, not one. New York has (A) only. California adds (B), and (B) is entirely within the insurer's control. Inform the claimant in writing of the right to choose, and the bar on recommending lifts.

That is the reverse of the New York arrangement, using the same raw material. Same notice, opposite function: in New York a compulsory announcement that leaves the rule intact, in California the condition that switches the rule off.

§ 758.5(b)(2) then tells the insurer what it may say once unlocked: "specific truthful and nondeceptive information regarding the services and benefits available to the claimant during the claims process", which "may include, but is not limited to, information about the repair warranties offered, the type of replacement parts to be used, the anticipated time to repair the damaged vehicle, and the quality of the workmanship available to the claimant."

And then the part that matters most, § 758.5(b)(3):

"If an insurer's recommendation of an automotive repair dealer is accepted by the claimant, the insurer shall cause the damaged vehicle to be restored to its condition prior to the loss at no additional cost to the claimant other than as stated in the policy or as is otherwise allowed by law."

California does not just regulate the sales pitch. It attaches a consequence to a successful one. If the insurer recommended the shop and you took the recommendation, the insurer owns the outcome: pre-loss condition, no additional cost to you. The section also addresses oral recommendations, requiring that the same information be given to the claimant when the recommendation is made that way.

No other state on this page does that. New York and Connecticut regulate what may be said. California regulates what happens next.

Connecticut: recommending is fine, but one sentence is banned

Conn. Gen. Stat. § 38a-354 is titled "Automobile appraisers and insurers prohibited from requiring where repairs should be made or making certain statements. Notice required on appraisals or estimates." Every distinctive thing about it is in that title.

§ 38a-354(a): "No automobile physical damage appraiser shall require that appraisals or repairs should or should not be made in a specified facility or repair shop or shops."

The appraiser is bound directly, as a licensed individual, not merely as the insurer's agent. And note "should or should not". Connecticut reaches negative steering, being told where not to go, which the other two sections do not address in terms.

§ 38a-354(b) binds the carrier side: "No insurance company doing business in this state, or agent or adjuster for such company shall (1) require any insured to use a specific person for the provision of automobile physical damage repairs, automobile glass replacement, glass repair service or glass products, or (2) state that choosing a facility other than a motor vehicle repair shop participating in a motor vehicle repair program established by such company will result in delays in repairing the motor vehicle or a lack of guarantee for repair work."

Two things there are unusual.

First, there is no bar on recommending. Subsection (b)(1) bars requiring. Connecticut leaves the insurer free to suggest a shop, with no notice condition and no express-request condition, because it has chosen to police the pitch rather than forbid it.

Second, (b)(2) bans a specific sentence. Not a category of conduct. The actual claim that "if you go elsewhere it will take longer and the work will not be guaranteed." That is the steering script itself, written into the statute and prohibited. It is the most operationally specific provision on this page: a shop or consumer does not have to characterise anything, only to notice whether those words were said.

§ 38a-354(c) requires the notice, on "Any appraisal or estimate for a motor vehicle physical damage claim written on behalf of an insurer", "printed in not less than ten-point boldface type":

"NOTICE: YOU HAVE THE RIGHT TO CHOOSE THE LICENSED REPAIR SHOP WHERE THE DAMAGE TO YOUR MOTOR VEHICLE WILL BE REPAIRED."

And glass is written in, not carved out. Subsection (b)(1) names "automobile glass replacement, glass repair service or glass products" expressly. New York excludes glass-only claims from its recommending bar. Connecticut goes out of its way to include glass.

The same three laws, side by side

Every row in that table is a place where a shop or a consumer who assumed the law is "the same everywhere" would get it wrong.

What this means if you are the one being steered

Work out which verb applies. Were you required, or recommended? Every one of the three bars requiring. Only two bar recommending, and one of those lifts the bar once you have been given a written notice.

In Connecticut, listen for the sentence. If anyone told you that using your own shop means delays or that the work will not be guaranteed, that specific representation is what § 38a-354(b)(2) prohibits. You do not need to argue about whether it amounted to steering.

In California, if you took their recommendation, read 758.5(b)(3) before you accept a repair you are unhappy with. The obligation to restore the vehicle to pre-loss condition at no additional cost is attached to the recommendation being accepted.

In New York, on a glass-only claim, the recommending bar does not apply. That is a real carve-out and it is the kind of thing people are surprised by after the fact.

Check the notice. Two of the three tell you the required wording and the minimum type size. A notice that is missing, or set smaller than the statute says, is itself a defect worth raising.

What we are not saying

• We are not saying these are the only three states with anti-steering law. They are the three we read first-party for this page. Others have provisions and one of them, described below, works differently again.
• We are not saying steering is unlawful in Connecticut. Connecticut bars requiring and bars one specific statement. Recommending a shop is not prohibited by § 38a-354.
• We are not claiming a notice defect makes the repair free. It is a statutory failure worth raising with the regulator. What follows from it is not something this page determines.
• We are not giving legal advice. These are statutes read and quoted. What they mean for a particular claim is a question for a lawyer or the state regulator.

What we could not verify

• Massachusetts, which appears to take a fourth approach entirely. Rather than prohibiting steering, Massachusetts appears to regulate the referral programme itself. The regulation that carries it is 211 CMR 123.00, Direct Payment of Motor Vehicle Collision and Comprehensive Coverage Claims and Referral Repair Shop Programs, whose section 123.06 is headed Referral Repair Shop Programs. Two neighbouring regulations are separate instruments and are not that one: 211 CMR 133.00 is Standards for the Repair of Damaged Motor Vehicles, and 211 CMR 135.00 covers referrals to motor vehicle glass repair shops. We identified all three from the Division of Insurance's own regulatory listing and did not read the regulation first-party this pass, so Massachusetts is named here as the next thing to read rather than counted above.

Corrected 2026-08-21; see Corrections below.

• Whether any of the three has been enforced, and with what result. We read the statutes. We did not search enforcement actions, market conduct examinations or case law.
• What the other 48 jurisdictions do, on this page. This is a mechanism comparison of three statutes, not a fifty-state survey, and it should not be read as one. We have since swept all 51 and the answer for every other jurisdiction is in what your insurer owes you if it picks the shop. What that sweep found is that these three are unusual: a flat prohibition is rare, and most states attach a duty to steering instead of forbidding it.
• Whether New York's glass carve-out is filled by another provision elsewhere in the Insurance Law or by regulation. We read § 2610 and noted the carve-out on its face.
• How California's 758.5(b)(3) obligation interacts with the policy limits referenced in its own text at "other than as stated in the policy or as is otherwise allowed by law."

Sources

• N.Y. Ins. Law § 2610, Collision or comprehensive coverage on motor vehicles; claims; repairs, Insurance (ISC) Chapter 28, Article 26, read first-party on 2026-08-19 from the New York State Senate's Open Legislation, which shows the displayed text as the most recent revision, dated 2017-06-23. Subsections (a), (b) and (c) quoted above.
• Cal. Ins. Code § 758.5, in Division 1, Part 2, Chapter 1, Article 5.1, Unlawful Practices, read first-party on 2026-08-19 from the California Legislative Information site. Subsections (a), (b)(1), (b)(2) and (b)(3) quoted above.
• Conn. Gen. Stat. § 38a-354 (formerly § 38-175u), read first-party on 2026-08-19 from the Connecticut General Assembly's published Chapter 700, Property and Casualty Insurance. Subsections (a), (b) and (c) quoted above. History as printed: P.A. 79-624; P.A. 92-259; P.A. 08-146, S. 1; P.A. 09-237, S. 2.
• Massachusetts 211 CMR 123.00, Direct Payment of Motor Vehicle Collision and Comprehensive Coverage Claims and Referral Repair Shop Programs, and its neighbours 211 CMR 133.00 (Standards for the Repair of Damaged Motor Vehicles) and 211 CMR 135.00 (glass referrals), identified from the Division of Insurance's own regulatory review listing and not read first-party. Named in What we could not verify, not relied on.

Corrections

2026-08-21. The wrong Massachusetts regulation. From the day this page shipped until today, the Massachusetts entry under What we could not verify said that 211 CMR 133, Standards for the Repair of Damaged Motor Vehicles, "governs referral repair shop programs." The title was right and the attribution was wrong. 211 CMR 133.00 is a separate instrument about repair standards. The regulation that governs referral repair shop programmes is 211 CMR 123.00, and its section 123.06 carries that heading. The entry now names all three neighbouring regulations and what each one is. The mistake came from reading a regulatory index at a glance and pairing a title with a subject that sat next to it; nothing on the page ever rested on it, because Massachusetts was named and deliberately not counted throughout.

2026-08-21. The headline claimed more than three states. This page was called Three States Ban Steering, and No Two of Them Ban the Same Thing. Read as a headline, "three states ban steering" says only three do, and a 51-jurisdiction sweep finished the same day disproved it: dozens of jurisdictions regulate repair direction, and most of them do it by attaching a duty to steering rather than by forbidding it. The comparison of these three statutes is unchanged and is still the deepest thing here. The title now names the three states instead of counting them, and the survey lives at what your insurer owes you if it picks the shop. The URL was deliberately not moved, so nothing that ever linked here is broken.

• What your insurer owes you if it picks the shop, in all 51 jurisdictions
• New York: your insurer may not even suggest a shop
• Who is allowed to set your claim number
• When insurance will not pay for a proper repair
• How our data is verified

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

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