Almost No State Bans Steering. Most of Them Put a Price on It.

Short answer: few states forbid an insurer from pointing you at a shop. What most do instead is let it point, then make it pay for pointing. In California the duty attaches when you accept the recommendation (Cal. Ins. Code § 758.5), and in South Dakota the insurer owes it whether it pointed at anyone or not (SDCL §§ 58-12-16, 58-12-17, 58-12-18). Each row below carries the citation we read and the date we read it.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-08-23 · 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, with the tables on this page built from a register by a script. How this site is written

The duty is remarkably consistent. Over and over, in statute after statute, it is the same sentence: the insurer shall cause the vehicle to be restored to its condition prior to the loss, at no additional cost to you. What is not consistent is the event that switches that duty on. In one state it is you accepting the recommendation. In another it is the insurer choosing to repair rather than write a cheque. In another it is simply running a network at all. We found seven distinct triggers.

So the useful question is not "does my state ban steering". It is "if my insurer sends me somewhere, what does it then owe me?" This page answers that for every US jurisdiction.

All 51 US jurisdictions are named on this page, and each one carries the statute or regulation citation we read to say what we say about it.

The finding, stated plainly

We swept all 51 jurisdictions for repair-direction law, which is wider than steering on purpose: the duty that attaches when an insurer designates a shop, the estimate rules that decide which shop can afford the job, the parts provisions, and who is allowed to complain.

A flat prohibition on steering is rare. A price on steering is close to universal. That is the whole shape of this area of law, and it is invisible if you go looking state by state for the word "steering", because most of these provisions never use it.

Two consequences follow for anyone actually in a claim:

• Knowing your state "has no anti-steering law" tells you almost nothing. Missouri has no shop-choice provision at all and still makes the insurer answerable for the quality of a repair at a shop it required you to use. Indiana regulates the part and says nothing about the shop. Wisconsin does not care what the insurer says to you; it cares whether your claim slowed down because of which shop has the car.
• The trigger matters more than the prohibition. In California the duty attaches when you accept the recommendation. In South Dakota it attaches to nothing at all: it is simply owed.

What fires the duty, jurisdiction by jurisdiction

Twenty-two jurisdictions answer the question directly: their statute or rule names an event, and once that event happens the insurer owes the repair. There are seven different events, and the state you are in decides which one applies to you. The table below has 25 rows rather than twenty-two because Iowa, Massachusetts and New Jersey each fire on more than one.

Every jurisdiction, and what we read to say so

All 51 US jurisdictions are named below, and 51 carry a citation to an instrument we opened ourselves, with none taken on trust from a listing or a mirror. 43 jurisdictions were read first-party in full; the rest say which kind of short they are.

The things worth knowing, wherever you are

Three states give the shop standing of its own, and one of them gives it a hearing

Everywhere else in this register the protected party is the consumer, and the repair shop is a bystander to enforcement. Three states write the shop in, and they do not do it to the same degree.

Colorado, C.R.S. § 10-4-120(5): "A beneficiary, claimant, or repair business may submit a written, documented complaint to the commissioner alleging a violation of this section."

Texas, Ins. Code § 1952.306: "A beneficiary, third-party claimant, or repair person or facility may submit a written, documented complaint to the department with respect to an alleged violation of this subchapter."

Both of those are a right to complain to the regulator. Massachusetts goes further and gives the shop a forum against the insurer. Under 211 CMR 123.06(4), an insurer may deny a shop's request to become a referral shop, or revoke an existing agreement, only by filing a statement with the Commissioner specifying the failure. And then:

"A repair shop which claims that it has been improperly denied as a referral shop or whose referral shop agreement has been revoked may demand arbitration."

Binding arbitration, before a neutral arbitrator the parties agree on or, failing agreement within 21 days, one the Commissioner picks. Costs are shared, but "the losing party shall be liable to the prevailing party for its costs", and if the arbitrator finds the losing party acted in bad faith it may award attorney's fees.

That is the difference between being allowed to report a problem and being allowed to contest the decision. If you run a shop, it is the single most actionable thing on this page.

The same right to choose, opposite economics

Every state that gives you a choice of shop has to answer a second question: what happens to the money if you use it. They do not agree, and the disagreement is stark.

Oregon forbids capping it. ORS 746.280(3): if you go somewhere other than the recommended shop, the insurer "may not limit the cost of repairs necessary to return the motor vehicle to a preloss condition relative to safety, function and appearance other than as stated in the policy or as otherwise allowed by law."

Nebraska pins it to the cheapest estimate on the file. Neb. Rev. Stat. § 44-1540(16): "If the insured or claimant chooses to use a particular company or location other than the one providing the lowest estimate for like kind and quality motor vehicle repair, the insurer shall not be liable for any cost exceeding the lowest estimate."

New Hampshire defines the ceiling by pointing at a shop that would actually do the work. RSA 417:4, XX(c) sets the benchmark as the price available from a "recognized, competent and conveniently located, independent repair shop or facility which is willing and able to repair the damaged automobile within a reasonable time."

Same right, three different answers about what it costs you to use it.

The strongest single duty found anywhere is in Alaska

Most states make the insurer answer for the outcome. Alaska makes the person adjusting the claim guarantee the work personally.

3 AAC 26.080(f): "If a person adjusting or settling a claim elects to have repaired a claimant's motor vehicle and chooses a specific facility for the repairs, that person shall guarantee the repairs and cause the damaged motor vehicle to be restored to its condition before the loss, at no additional cost to the claimant, and cause the repairs to be completed within a reasonable time."

Three obligations in one sentence: guarantee it, restore it, finish it in reasonable time. New Jersey requires the insurer to select a shop that gives a written guarantee. Alaska puts the guarantee on the adjuster.

Vermont states the same idea in one line and nothing else. Insurance Regulation I-79-2, § 8(A)(3), in its entirety: "If insurer insists that repairs be done by a specific repairer, said insurer shall guarantee all work performed by said repairer." No restoration language, no pre-loss condition, no cost qualifier. Insist, and you own the work. Massachusetts adds that the guarantee cannot be waived; Alaska adds restoration and a time limit; Vermont just makes it follow.

Vermont is the only state that tells you what "matching" means

Anyone who has argued about a blended panel knows the problem: the replacement part is the right part and the car still looks wrong. One jurisdiction in fifty-one defines the standard.

Insurance Regulation I-79-2, § 8(A)(6), Matching of Exterior and Interior Partial Losses: when a covered loss requires replacement and the new items "do not match adjacent items in quality, color or size, the insurer shall replace such items with material of like kind and quality so as to conform to a reasonably uniform appearance within the same line of sight, taking into account natural breaks. The insured shall not bear any cost over the applicable deductible, if any."

Within the same line of sight, with natural breaks accounted for, and the cost of getting there is not the customer's. Vermont also carries two other duties found nowhere else in this register: § 8(A)(2) makes the insurer "make every reasonable effort to reach an agreed price with the repairer" the claimant chose, and § 8(A)(5) makes it "advise claimant of and pay for all known hidden damages attributable to the accident or loss."

Massachusetts bans referral outright, then licenses it in one place and regulates that place hard

This is the most developed scheme in the register, and its shape is the interesting part. The general rule binds the appraiser and is the only one of its kind anywhere:

212 CMR 2.04(1)(c): "No staff or independent appraiser, insurer, representative of insurer, or employer of an independent appraiser shall refer the claimant to or away from any specific repair shop or require that repairs be made by a specific repair shop or individual."

"To or away from." No other jurisdiction read bars steering a customer away from a shop, and for a shop that has been badmouthed to its own customer that is the more useful half.

Then the very next sentence switches it off in one place: "The provisions of 212 CMR 2.04(c) shall not apply to any approved direct payment plan pursuant to 211 CMR 123.00." Reading the bar without the carve-out would tell you Massachusetts forbids something it permits every day. What makes the scheme work is what 211 CMR 123.00 then demands of the programme:

• One list, and no short list. 123.06(2)(a): every claimant gets "a single list containing the names and locations of all registered repair shops" from the Division of Standards register. The insurer may asterisk at least five convenient referral shops, and then: "An insurer shall not provide a separate list containing only its referral shops." Nowhere else is the network-only list forbidden.
• A closed set of reasons. 123.06(3)(b): the insurer "shall consider all of the following criteria, and only the following criteria" in choosing referral shops, and the seven are listed. Its written guidelines are deemed part of its filed plan and must be handed to any shop it denies or drops.
• The guarantee, and it cannot be waived. 123.06(5): use a shop on the insurer's list and "the insurer shall guarantee the quality of the materials and workmanship used in making the repairs. No insurer may petition the Commissioner for a waiver of this requirement."
• You are out of the argument. 123.05(4)(d): at a referral shop, neither the shop nor the insurer may make you pay more than the direct payment plus your deductible, and any dispute over the appraised damage "shall be resolved between the referral repair shop and the insurer."
• Reinspection cannot be used as punishment. 123.06(6) sets the reinspection rates and then bars choosing vehicles by the policyholder's age or sex, where the car is garaged, "or on whether the repairs were performed at a repair shop that is not a referral repair shop."

Two more Massachusetts rules matter to anyone writing estimates. 212 CMR 2.04(1)(e) bars an appraiser from modifying any published manual "without prior negotiation between the parties" and from using "more than one manual or system for the sole purpose of gaining an advantage in the negotiation process." Montana bars disregarding an agreed estimating system; Massachusetts bars editing it and bars shopping between systems. And 211 CMR 133.04(2) puts the risk of the insurer's parts choice on the insurer: when it specifies used, rebuilt or aftermarket parts the source and specific parts must appear on the appraisal, and if those parts turn out unfit "the insurance company shall be responsible for the costs of restoring the parts to usable condition" plus freight and handling on the replacements.

The rest of the programme family, and the state that inverts it

Massachusetts above is the most developed of these. Three other jurisdictions regulate the direct repair programme itself rather than the act of steering, and no two of them pick the same lever.

Montana, Mont. Code Ann. § 33-18-224(2), conditions who may be in a direct repair programme at all. An insurer running one "may not limit the number" of shops in it except by stated criteria, one of which is that the shop "agrees to warrant the quality of work, including refinishing, in writing to the claimant, for a period of not less than 1 year from the date of repair." Montana also carries the only line-item rule found anywhere: an insurer may not "unilaterally disregard a repair operation or cost identified by an estimating system" that it and the shop agreed to use.

Hawaii, HRS § 431:10C-313.5, conditions the money and the choice instead. An insurer with a preferred repair provider programme must make rate filings "to reflect the reduced premiums" and must "offer a choice of no less than two preferred repair providers to the claimant, if available."

South Dakota turns it round entirely. SDCL § 58-12-18 makes a network a way to comply: "An insurer may comply with 58-12-16 by entering into an agreement with a repairer that guarantees repairs and by notifying the insured of such an agreement." Montana makes the network a regulated thing. South Dakota makes it a safe harbour.

Minnesota is the only state that tells the insurer to stop talking

Every other state regulates what may be said before you choose. Minnesota regulates what happens after.

Minn. Stat. § 72A.201, subd. 6, cl. (7): "After an insured has indicated that the insured has selected a repair shop, the insurer must cease all efforts to influence the insured's or claimant's choice of repair shop."

Minnesota also writes the advisory word for word, to be given when the claim is reported: "You have the legal right to choose a repair shop to fix your vehicle. Your policy will cover the reasonable costs of repairing your vehicle to its pre-accident condition no matter where you have repairs made. Have you selected a repair shop or would you like a referral?"

Wisconsin names the slow-walk

Steering is not always a sentence someone says to you. Sometimes it is a claim that stops moving until you give in. Wisconsin is the only state read that names that directly.

Wis. Stat. § 632.375(2)(b): "No insurer may fail to initiate and conclude with due dispatch an investigation of a claim for repairs to a motor vehicle on the basis of whether the repairs will be made by a particular contractor or repair facility."

The same limb in three states, with one word changed

Three states carry what is recognisably the same provision, and no comparison by section heading would ever surface it, because the wording of the standard is different in each.

Repairs by a shop the insurer owns or requires you to use must be performed in a:

• "workmanlike manner" in Missouri, RSMo 375.1007(14)
• "professional manner" in Maine, 24-A M.R.S. § 2164-D(3)(L)
• "skillful manner" in Nebraska, Neb. Rev. Stat. § 44-1540(15), which also defines affiliation by contract

None of the three regulates shop choice. All three regulate the consequence of having steered.

Michigan makes the insurer tell you it has a network, before you file

Other states make the insurer disclose your right to choose. Michigan also makes it disclose its own arrangements.

MCL 500.2110b(2): the insurer "shall disclose, prior to or at the time a claim is filed, whether the insurer has an agreement with any repair or replacement facility" and shall inform you that you are "under no obligation to use a particular repair or replacement facility."

Michigan's standard is also unusual in kind: § 2110b(1) forbids unreasonably restricting your choice rather than forbidding restriction outright. What counts as unreasonable is not defined in the section.

One state moved backwards this year, and said so in the statute

Utah H.B. 119 of 2026 amended Utah Code § 31A-22-319. It repealed the shop-side duty to give the consumer written notice before installing non-original parts, added a subsection disclaiming warranties, and added a new subsection (5) providing that, notwithstanding Sections 31A-2-101 and 31A-2-201, the department and the commissioner are not required to administer or otherwise enforce Subsection (3), which is the estimate-disclosure duty created by the same act.

A state wrote a disclosure duty and, in the same act, relieved its own regulator of enforcing it. Nothing else in this register does that.

Where this law actually lives, which is usually not where you would look

The unfair claims settlement practices chapter, which is where anyone would start, was read and found empty in seventeen jurisdictions. The provision was somewhere else:

• adjuster or appraiser licensing in Maryland, Rhode Island, Delaware, North Carolina, South Carolina and Minnesota
• rate regulation in Michigan, chapter 21 rather than chapter 20
• casualty insurance in Nevada
• the claims and benefits chapter in South Dakota
• the motor vehicle code, not the insurance code, in Mississippi and Michigan
• the consumer protection code in Arkansas and West Virginia
• trade and commerce in Louisiana
• an administrative rule with no statutory parent in Nebraska
• a rule, because the state code itself is behind a commercial paywall, in Tennessee, Georgia, Arkansas and Mississippi
• a bill rather than a code section in Utah, where the operative 2026 amendment is readable only as the enrolled H.B. 119

If you searched your state's unfair claims chapter and found nothing, that is not an answer. It is one chapter.

What to do with this if you are the one being steered

Find your row above and read the trigger, not the prohibition. The question that decides your claim is usually not "was this allowed" but "what did it switch on".

If your insurer picked the shop, find out what that costs it. In roughly twenty jurisdictions the answer is a specific, quotable duty owed to you, and the citation is in the table.

If you are a shop in Colorado or Texas, you can complain in your own name, and in Massachusetts you can demand arbitration. Everywhere else the complaint has to come from the customer.

Do not assume silence means no protection. Several states with nothing on shop choice still regulate the parts, the estimate, the payment, or the speed of the claim.

Check what the notice was supposed to say. Fourteen jurisdictions require a notice of your right to choose, and five of them write the sentence out word for word. A notice that is missing, or worded differently from the statute, is a defect worth raising.

What we are not saying

• We are not saying your insurer cannot recommend a shop. In most of these jurisdictions it can. What this page is about is what follows once it does.
• We are not saying a state with no provision leaves you unprotected. Your policy, the general unfair claims practices law, and consumer protection statutes all still apply. This page is about repair-direction provisions specifically.
• We are not claiming any of these provisions has been enforced. We read the instruments. We did not search enforcement actions, market conduct examinations or case law, and a provision on the books is not a prediction about any insurer's behaviour.
• We are not giving legal advice. These are statutes and rules, read and quoted. What any of them means for a particular claim is a question for a lawyer or your state regulator.

What we could not verify

• Massachusetts 211 CMR 135.00 and 211 CMR 56.00. We read 211 CMR 123.00, 211 CMR 133.00 and 212 CMR 2.00 in full. Two neighbouring regulations were located on the Division of Insurance's own index and not read: 135.00, on referrals to motor vehicle glass repair shops, and 56.00, which reduces the premium for drivers who accept a participating-repair-shop endorsement. The second is Hawaii's rate-filing idea approached from the opposite end and it is named here and not counted.
• Kansas cannot be called either way. K.A.R. 40-1-34 does not write its own standards. It adopts by reference the NAIC Unfair Claims Settlement Practices Model Regulation, January 1981 edition, subject to lettered exceptions. The standards that would answer this page's question are inside that incorporated document, which is not published on any Kansas government host. A word search of the Kansas rule comes back nearly empty, and reporting that as a negative would be wrong.
• The rest of one Mississippi bulletin, which is the last unread page in this survey. Bulletin 98-7 named the statute for us and we could not finish reading it. It is a fax scan with no text layer: pdftotext returns a single character from 74,113 bytes. Rendering it in a browser and looking at it got the letterhead, the date, the addressee, the full statutory heading, the directive to insurers, and the first clause of the quoted section, before the viewer refused to scroll under automation. So Mississippi's row is marked read as to the bulletin only, and it is not counted among the jurisdictions whose provision we can quote. A citation and a first clause are not a provision.
• Wyoming's administrative rules. Wyoming's negative above covers the Insurance Code, which is what it says: we searched the whole of Title 26, 1,944,977 characters, and counted zero occurrences of "repair shop", "body repair" and "aftermarket crash". We did not enumerate the department's rules.
• Whether any provision has been amended since the date in its row. Each row carries the date it was read.

Sources

Every jurisdiction's citation, evidence tier and reading date is in the table above, generated from data/compliance/repair-direction-by-state.json rather than typed. The instruments quoted in the sections above were read first-party on a government host on the dates their rows carry:

• Alaska, 3 AAC 26.080, Alaska Administrative Code, read 2026-08-21.
• Colorado, C.R.S. § 10-4-120, read 2026-08-19 for data/compliance/anti-steering-mechanisms.json and reused here.
• Hawaii, HRS § 431:10C-313.5, read 2026-08-21. History as printed: L 1997 c 251, pt of s 2.
• Maine, 24-A M.R.S. § 2164-D(3)(L), read 2026-08-21. Added by PL 1997 c. 634 Pt. A s.1.
• Massachusetts, three instruments read in full on 2026-08-21 from the Commonwealth's own host: 211 CMR 123.00, Direct Payment of Motor Vehicle Collision and Comprehensive Coverage Claims and Referral Repair Shop Programs, seven pages, carrying Mass. Register #1560, 7 November 2025; 211 CMR 133.00, Standards for the Repair of Damaged Motor Vehicles, four pages; and 212 CMR 2.00, The Appraisal and Repair of Damaged Motor Vehicles, six pages, made by the Auto Damage Appraiser Licensing Board under M.G.L. c. 26, § 8G.
• Michigan, MCL 500.2110b, read 2026-08-21. Added by 2004 Act 190, immediately effective 8 July 2004.
• Minnesota, Minn. Stat. § 72A.201, subd. 6, read 2026-08-21.
• Missouri, RSMo 375.1007(14), read 2026-08-14 for data/compliance/ucspa.json and reused here.
• Montana, Mont. Code Ann. § 33-18-224, read 2026-08-21 from the Montana Code Annotated 2025.
• Nebraska, Neb. Rev. Stat. § 44-1540(15) and (16), read 2026-08-21. Source: Laws 1991 LB 234 s.22, as amended through 2011 LB 72 s.5.
• New Hampshire, RSA 417:4, XX, read 2026-08-21.
• Oregon, ORS 746.280 and ORS 746.285, read 2026-08-21. History as printed: 1977 c.785 s.2; 2007 c.506 s.1.
• South Dakota, SDCL §§ 58-12-16, 58-12-17 and 58-12-18, read 2026-08-21. Source for 58-12-15 to -18: SL 2000 ch 239.
• Texas, Tex. Ins. Code §§ 1952.301 to 1952.307, read 2026-08-21 in a browser. Added by Acts 2005, 79th Leg., ch. 727 (H.B. 2017), s.2, effective 1 April 2007.
• Mississippi, Insurance Department Bulletin No. 98-7, 27 August 1998, over Commissioner of Insurance George Dale and Deputy Commissioner Ronald E. Hanna, read on the department's own host on 2026-08-21 as far as the scan allowed. It is the source for the existence and heading of Miss. Code Ann. § 83-11-501, in Title 83, chapter 11, article 9, Repairs to Damaged Vehicles.
• Utah, Utah Code § 31A-22-319 as amended by 2026 Utah Laws H.B. 119, enrolled bill text read 2026-08-21; Utah Admin. Code R590-190-12 read in full the same day.
• Vermont, 8 V.S.A. § 4724(21), and Insurance Regulation I-79-2 (revised effective 1 July 2018), Fair Claims Practices, section 8 read in full on 2026-08-21 from the Department of Financial Regulation's own host.
• Wisconsin, Wis. Stat. § 632.375, read 2026-08-21.

Corrections

2026-08-21, hours after publication. We said Massachusetts could not be read, and the obstacle was our own typo. This page shipped saying the Commonwealth's host refused our reader and that Massachusetts was named but not counted. That was wrong. The document URL we had been retrying carried 211-cmr-123 where the real address is 211-cmr-12300. A wrong URL returns 404, and at some point a 404 became "mass.gov returns 403 on every URL", a claim about a whole host that was never tested against an address known to be right. Opening the Division of Insurance's regulations index in a browser and reading the link out of the table produced the correct address, and all three Massachusetts instruments then downloaded on the first attempt. The page now reports Massachusetts as read in full, and it turned out to carry the most developed scheme in the register.

The rule we took from it, which is now in the register: before recording a host as walled, prove the URL resolves for a document you know exists. A wall is not a verdict about a host until the address has been checked.

Then we applied that rule to the rest of the list, and three more rows moved. Vermont's Fair Claims Practices regulation was recorded as unreachable; the address was right and the refusal was real, but the regulator's own site served it to an ordinary browser, so section 8 is now read in full and Vermont turns out to hold the only definition of matching within the same line of sight in the country. Utah's claims rule was recorded as a 404; it is a browser-only application, and reading it confirmed first-party what a commercial mirror had only suggested. Mississippi's bulletin really is an unreadable scan, but looking at it named a statute this survey did not know existed: Miss. Code Ann. § 83-11-501, in the insurance title, while we had been citing only the parts chapter in the motor vehicle title. Mississippi's row was the weakest here because we had been reading the wrong title.

One correction belongs to its companion page and is named here because it concerns the same jurisdiction. The three-state comparison previously attributed 211 CMR 123.00's subject matter to 211 CMR 133.00, which is a different Massachusetts regulation with a different title. That was corrected on 2026-08-21 and the correction is logged on that page.

• New York, California and Connecticut, the three flat prohibitions, compared clause by clause
• New York: your insurer may not even suggest a shop
• 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.

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.

• The Rate Loop: How the Prevailing Labour Rate Is Set (the survey and the contract clause behind the rate the network shop is offered)
• Who Actually Signs the Agreement With Your Insurer (who holds the contract behind the network shop, which is not always the shop)
• Who Pays for Your Collision Repair, and What the Documents Show (the twenty investigations behind the rules on this page, grouped by what you are trying to find out)
• The Money On Top Of The Number (sales tax, title and registration on a total loss, and whether anyone has to tell you)