Who Is Legally Allowed to Write Your Repair Estimate

Short answer: it depends on the state, and on which licence you read. New York bars an insurer's unlicensed staff from writing or supervising a motor vehicle body repair estimate. Texas exempts "an estimator" by name. The governing licence is the auto damage appraiser licence, not the adjuster licence.

By Anthony Braswell for Quorum Industries LLC, The Autobody Directory · Updated 2026-09-02 · 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

In some states it is unlawful for an unlicensed person to write your collision estimate. In others the law names that person and exempts him by title. The claim you hear across the collision repair trade, that carriers put unlicensed people on estimates and have a licensed person sign off on the money, is neither the scandal it is presented as nor the myth insurers say it is. It is a description of an arrangement that is expressly lawful in one large state and an express statutory violation in another.

The reason the argument never settles is that both sides have been reading the wrong licence.

The industry has been counting the wrong thing

A list circulates through the adjusting business of states that do not license adjusters. WebCE's version names sixteen jurisdictions under the heading "states that do not license adjusters": Colorado, the District of Columbia, Illinois, Kansas, Maryland, Massachusetts, Missouri, Nebraska, New Jersey, North Dakota, Ohio, Pennsylvania, South Dakota, Tennessee, Virginia and Wisconsin.

Massachusetts and Pennsylvania are on it.

Massachusetts operates the most restrictive regime found in this research for the act of writing a vehicle damage estimate. Pennsylvania requires an appraiser's licence number on the face of every appraisal and fines carriers when it is missing. Neither state licenses the general adjuster, so both are correctly placed on a list about adjuster licensing, and both are badly misdescribed by it. The WebCE page, read on 2026-09-01, makes no reference to auto damage appraiser licensing anywhere, and carries no date.

That is the whole problem in one line. "Adjuster" and "auto damage appraiser" are two different licences with two different subject matters, and in every state examined here the estimate is governed by the second. Counting the first produced a map that was wrong in both of the two entries on that list we checked against their own statutes.

The negative control: one regulator, one programme, three carriers, three answers

The most honest evidence located in this research is a comparison, not an allegation.

The Delaware Insurance Department checks adjuster licensing systematically in market conduct examination. The licensing provision is 18 Del. C. 1703, which both reports that recorded exceptions cite. Three carriers went through that programme and produced three different results.

• Travelers, examination period 1 January 2020 to 31 December 2022, covering Travelers Home & Marine, Travelers Commercial and Standard Fire: "There were 16 claims adjusters not licensed from their applicable date of licensing and the claim loss date." The report closed with a recommendation, not a penalty. Source
• GEICO, claims examination period 1 January 2021 to 31 December 2023, covering seven GEICO entities: "Three claims' adjusters were not licensed from their applicable date of licensing and the claim loss date." No monetary penalty stated. Source
• State Farm, examination period 1 January 2017 to 31 March 2022, covering State Farm Mutual Automobile and State Farm Fire & Casualty: "During the review of Claims, the examiners randomly selected adjusters to verify their licensing, utilizing the verification service from the Department in coordination with the NAIC. No exceptions were noted." Source

Sixteen, three, and none. Same regulator, same licensing requirement, same examination programme, three answers. One limit on that comparison, which we can measure and therefore state: only the State Farm report describes how the examiners tested. Its phrases "randomly selected adjusters", "verify their licensing" and a request for a list of licensed adjusters appear in that report and in neither of the other two, on a string search whose positive control confirms the word "adjuster" itself appears four times in the GEICO report. So the third column is a sampling result that found nothing, and the first two are findings whose method the reports do not record. Three Delaware market conduct examinations under one statute is what this is. Three runs of an identical test is not something the documents establish.

That comparison does more work than any individual finding. It establishes that unlicensed claims handling is real, that it recurs, and that in the one state examined here it tracks the carrier rather than the industry. Anyone citing the Travelers number as proof of how the industry operates has to explain the State Farm result, and anyone citing the State Farm result as proof that the complaint is imaginary has to explain the other two. Both of those arguments are made constantly. Neither survives the third column.

We are not saying that the three Delaware examinations describe the industry. They describe one state's programme, over three different periods, across three different sets of entities, with a random sample rather than a census behind the zero, and this page draws no national rate from them.

Vermont produced the one substantial penalty located in this research. In docket 21-024-I, ordered 8 December 2021, the Department of Financial Regulation concluded that Allstate violated 8 V.S.A. 4793(a), having "identified numerous claims that were settled without having been reviewed by a Vermont licensed adjuster," in a negotiated stipulation in which Allstate agreed to resolve the matter without a hearing and "do[es] not admit the existence of violations as set forth in this agreement." Allstate paid a $225,000 administrative penalty. No court has ruled on the conduct.

New York forecloses it by name

New York is the clearest statutory refusal of the practice found in this research.

Insurance Law 2101(g)(1) exempts a list of people from the definition of an adjuster, beginning at clause (A) with "any officer, director or regular salaried employee of an authorized insurer" and running on through managers, attorneys in fact of reciprocal insurers and marine underwriting offices. That is the ordinary staff exemption, the mechanism by which a carrier's payroll adjusters work claims in licensing states without personally holding anything. New York grants it, then immediately withdraws it, with the words "unless acting as an auto body repair estimator as defined in subsection (j) of this section."

The same carve-out is repeated in the clauses covering insurer employees otherwise licensed to write the insurance being adjusted, and adjustment bureaus owned and maintained by insurers. Staff and carrier-owned bureaus are all reached.

Subsection (j) supplies the definition, and it is the operative sentence for this subject. An auto body repair estimator is an officer, director or regular salaried employee of an authorized insurer, or of an adjustment bureau or association owned and maintained by insurers, "who writes, or who directly supervises the writing of, any motor vehicle body repair estimate in this state, on behalf of such insurer in the work of diagnosing or estimating motor vehicle repair costs or procedures relative to appraising, investigating or adjusting claims for motor vehicle body repair work pursuant to an insurance contract."

Read the two verbs. Writes, and directly supervises the writing of. New York attaches the licence to both ends of the arrangement the trade complains about: the unlicensed keyboard and the licensed signature above it are the same regulated act. On the text quoted above, there is no configuration of an estimating desk in New York in which only one of them holds the licence.

Texas codifies the opposite, and prices it cheaply

Texas writes the practice into its statute as an exemption, with the job titles spelled out.

Texas Insurance Code 4101.051 is conventional: "a person may not act as or represent that the person is an adjuster in this state unless the person holds a license under this chapter." Section 4101.002(a)(2) then narrows the staff exemption to "a salaried employee of an insurer who is not regularly engaged in the adjustment, investigation, or supervision of insurance claims," which is stricter than New York's general rule.

Then comes 4101.002(a)(3), which exempts "a person employed only to furnish technical assistance to a licensed adjuster, including: (A) an attorney; (B) an engineer; (C) an estimator; (D) a handwriting expert; (E) a photographer; and (F) a private detective."

An estimator. A photographer. Named in the statute, among people who may do the work without a licence provided a licensed adjuster is the one being assisted. The arrangement New York forecloses by name, Texas authorises by name, for the same conduct.

Texas also prices the breach at almost nothing. Section 4101.203 makes unlicensed adjusting a misdemeanor punishable by "a fine of not more than $500," "confinement in the county jail for not more than six months," or "both the fine and the confinement." In Florida, section 626.112(1)(a) bars any person from acting as an insurance adjuster without being licensed and appointed, and knowingly engaging in insurance activities without a licence in violation of that section is a felony of the third degree. The same conduct, a felony in one state and a $500 fine in another, explains more about compliance behaviour than any enforcement statistic located in this research.

There is an unresolved tension inside Texas itself. Commissioner's Bulletin B-0003-26 of 12 June 2026 states that "official acts of an adjuster include investigating or adjusting losses and supervising the handling of claims," that "certain acts may be taken only by a person who holds a license to act as an adjuster," and that "if a regulated entity uses AI to make a consequential decision, TDI expects a person to review and agree with all decisions before action is taken." That instrument insists on a licensed human at the decision point while 4101.002(a)(3) exempts the estimator and the photographer feeding the same file. Sourcing note: tdi.texas.gov returned HTTP 500 to every request made for this article, across two URL forms and a re-check on the date of publication. The quotations above come from a copy of the official bulletin PDF hosted by a third party. We do not claim that text is confirmed against the issuing agency; the official source was unreachable and the bulletin has not been checked against it.

Massachusetts, and a rule written before the technology it now blocks

212 CMR 2.02 is the bluntest sentence located in this research: "No person in Massachusetts shall appraise or estimate damages to motor vehicles or otherwise present himself or herself as an appraiser unless he or she has first obtained a license from the Auto Damage Appraiser Licensing Board."

Read against Texas, what the two Massachusetts sections read here do not contain is the point. No technical assistance exemption. No staff carve-out. No supervision structure that cures it.

Then 212 CMR 2.04 does something the drafters could not have intended in the sense it now carries: "The appraiser shall personally inspect the damaged motor vehicle and shall rely primarily on that personal inspection in making the appraisal." The same section requires that "as part of the inspection, the appraiser shall also photograph each of the damaged areas," and permits insurers to exclude losses under $1,500 net of deductible.

That clause is a pre-emptive bar on photo-only and AI-generated estimating above the $1,500 line, written decades before either existed. It is not a rule about artificial intelligence. It is a rule about a licensed human standing next to the car, and it is the only instrument located in this research that a photo estimate cannot satisfy however accurate it is.

Massachusetts has tested this directly and reversed itself. The Auto Damage Appraiser Licensing Board adopted Advisory Ruling 2014-01, treating appraisal by review of quality video or digital images as satisfying the personal inspection requirement, then repealed it by majority vote on 21 July 2015, warning that "failure of licensed appraisers to comply with this ruling could result in fines and penalties as provided for by law." The repeal gives no reasons, and none should be attributed to the Board.

The scale it sits against is not small. In the NAIC's private passenger auto survey, reported in December 2022, 55 companies reported AI or machine learning in use for evaluation of images of loss and 50 for determining settlement amounts, while zero reported any use for claim denial, with image models 72 percent third-party sourced and settlement-amount models 80 percent.

What Pennsylvania's violations actually are

Pennsylvania is routinely cited in this argument, and routinely overstated.

63 P.S. 861(b) requires that an appraisal "shall contain the name of the insurance company ordering it, if any, the insurance file number, the number of the appraiser's license and the proper identification number of the vehicle being inspected," along with "an itemized listing of all damages, specifying those parts to be replaced or repaired." A separate provision requires each appraiser to carry the licence issued by the Insurance Department and display it on request.

The Pennsylvania Insurance Department enforces this. In market conduct examination MC24-12-031, ordered 16 January 2025 against State Farm Mutual Automobile for the period 1 July 2022 to 30 June 2023, the Department imposed a $55,000 civil penalty. The 861(b) violations are itemised by claim category rather than totalled: five in property damage, five in collision, six in comprehensive and six in total loss, summing to twenty-two. The report states no consolidated figure.

Here is the part that gets misreported. Every one of those violations reads that "the appraisals were missing the appraiser's license number." They are documentation failures. The Department found appraisals that omitted a licence number; it did not find that the appraiser lacked one, and the report we read contains no unlicensed appraiser finding at all.

We are not claiming that Pennsylvania's record shows unlicensed people writing estimates. That distinction is not a technicality. A missing number on a form and an unlicensed person writing an estimate are different offences, and treating Pennsylvania's record as evidence of the second reads the record backwards. It is evidence of the first, which still matters: it shows a state auditing the identity of the person who wrote the estimate, which no other state examined here was found to do.

A second Pennsylvania consent order against Allstate Fire and Casualty, docket MC25-09-006, ordered 4 November 2025 for calendar year 2023, also found 861(b) violations for missing appraiser licence numbers and carried a $5,000 civil penalty. No violation count is published here: that report states no consolidated figure, successive reads of it have not agreed, and the number is not reliably established. An earlier Allstate Pennsylvania report from May 2024 was not examined.

What the licence actually tests

If a licence is the answer to who should write an estimate, it is fair to ask what the licence knows. The general adjuster licence and the auto damage appraiser licence do not test the same thing, and only one was verified here to test whether the holder understands how a car is repaired.

Massachusetts is that one. M.G.L. c. 26 section 8G creates a five-member Auto Damage Appraiser Licensing Board: four appointed by the governor, two of them affiliated with the auto body repair industry and two with insurers writing casualty insurance in the commonwealth, and a fifth appointed by the commissioner of insurance who is affiliated with neither industry and chairs the board. An applicant must be eighteen or over and of good moral character, must hold high school qualifications "or that he possesses relevant work experience deemed satisfactory by the board," and must pass an examination. Appraisals "shall be sworn to under the penalties of perjury and shall also include the appraiser's signature, license number, seal, fee charged and date the motor vehicle was examined." The rest of that section, including the anti-steering and supplement rules it carries, is covered in who is allowed to set your claim number and is not repeated here.

The preparation curriculum is where the asymmetry shows. The MassBay Community College programme covers "insurance regulations, policy arbitration, and work completion forms, use of Flat Rate Manuals, collision diagnosis, cost estimation and preparation of written estimates," runs in two parts matching the state examination, and satisfies the state's three-month apprenticeship requirement through a work experience letter from a licensed Massachusetts appraiser.

Flat rate manuals. Collision diagnosis. An apprenticeship under someone who already holds the licence. The state that most tightly controls who may write an estimate, among the states examined here, is the only one verified here to test whether that person understands the repair.

Other appraiser licensing states were verified to require the licence, but not to test repair knowledge. Connecticut bars any person from acting "as an appraiser for motor vehicle physical damage claims on behalf of any insurance company" without first securing a licence from the Insurance Commissioner, then expressly permits the Commissioner to waive the examination entirely for a nonresident holding an equivalent licence elsewhere. Rhode Island uses near-identical language, and North Carolina names the motor vehicle damage appraiser as a licensed category alongside the producer and the adjuster. Whether those examinations test repair competence was not established.

The lawful gap that opens after every catastrophe

The clearest example located here of the trade's complaint operating entirely within the law is not a loophole. It is a statute.

Florida Statutes 626.874 provides for emergency adjusters. Persons "who are residents or nonresidents of this state, who are at least 18 years of age, who are United States citizens or legal aliens who possess work authorization" may be appointed for "the period of emergency as it shall determine," provided an authorised insurer, or a licensed independent adjusting firm contracted with one, certifies them as qualified to act as adjusters. The statute describes these people as not licensed adjusters under that part.

The carrier certifies. The state accepts the certification. The person works claims. In the state that grades knowing unlicensed adjusting a third-degree felony, the licence requirement gives way after a catastrophe to the insurer's own attestation about people it has chosen. That is the complaint, legislated, and it switches on when claim volume is highest and consumer attention lowest.

The courts already answered the question the software raises

If an estimate is generated by software and reviewed by a person, whose judgment is in it? The federal courts answered that in litigation insurers mostly won, and the reasoning cuts against the industry's own position.

The wage and hour cases turned on whether adjusters exercise enough independent judgment to be exempt from overtime. The governing regulation, 29 C.F.R. 541.203(a), lists the qualifying duties as including "inspecting property damage; reviewing factual information to prepare damage estimates; ... determining liability and total value of a claim; negotiating settlements." The federal framework assumes the adjuster inspects the damage and prepares the estimate personally.

Insurers argued, successfully, that this is skilled discretionary work. In Roe-Midgett v. CC Services, the Seventh Circuit affirmed judgment for the employer and dealt directly with the software objection: "the adjusting manual and the estimating software are most accurately characterized as tools that channel rather than eliminate the MDAs' discretion." Those material damage appraisers held $12,000 of settlement authority, negotiated with body shops, made repair-versus-replace calls, and "spend much of their time in the field without direct supervision."

In Robinson-Smith v. GEICO, the D.C. Circuit reversed for GEICO, holding auto damage adjusters exempt. The record described an average adjuster handling "more than 1,000 claims per year, totaling over $2.5 million," settlement authority of $10,000 at Level I and $15,000 at Level II, and supervisory review that came only after the estimate was written and the claim paid. In In re Farmers Insurance Exchange Claims Representatives' Overtime Pay Litigation, the Ninth Circuit, in a disposition affirming in part and reversing in part, reversed an award of approximately $52.5 million to 1,039 adjusters and held them exempt.

The position insurers won is that writing an estimate on commercial estimating software is discretionary professional work done in the field with little real-time supervision. That sits badly beside the argument that the estimate writer is a clerical input a licensed adjuster merely approves. Both propositions are in the industry's own litigation record. What the personal licence does to that argument, and what an individual licence holder owes that an employer cannot spend, is the subject of adjuster scorecards and the personal licence.

The structural pressure is in the labour numbers. The Bureau of Labor Statistics counts 13,500 insurance appraisers in auto damage, projected to fall 9 percent over 2025 to 2035, partly because "computer software can evaluate photographs of damaged property and calculate an estimated claim amount." The same page records the mechanism this article is about: "In some states, claims adjusters employed by insurance companies do not have to become licensed themselves because they can work under the company license."

What we could not establish

The state-by-state picture is incomplete, and the gap is in a specific place. This article verified statutory or regulatory text in eight states: New York, Texas, Massachusetts, Pennsylvania, Connecticut, Rhode Island, North Carolina and Florida. In two more, Delaware and Vermont, we verified enforcement documents citing the licensing statute rather than the statute text itself. Everything else here rests on industry reporting.

That leaves fourteen jurisdictions whose status as non-licensing states comes only from industry lists and was never checked against their own statutes: Colorado, the District of Columbia, Illinois, Kansas, Maryland, Missouri, Nebraska, New Jersey, North Dakota, Ohio, South Dakota, Tennessee, Virginia and Wisconsin. Massachusetts and Pennsylvania were on the same list, and both turned out to license the estimate writer under a different statute with a different name. Two of that list's sixteen entries were checked against their own statutes for this article, and both were wrong about who may write an estimate. We do not claim to know what the other fourteen do, and neither does anyone repeating the list. An unverified state is not an unlicensed state.

We do not publish a violation count for the Pennsylvania Allstate order. That report states no consolidated figure and successive reads of it have not agreed. A separate May 2024 Allstate Pennsylvania report was not examined.

We could not reach the Texas Department of Insurance. Bulletin B-0003-26 is quoted from a third-party copy of the official PDF because tdi.texas.gov returned HTTP 500 to every attempt, across two URL forms and a re-check on the date of publication. Its robots file itself timed out. Treat those quotations as unconfirmed against the issuing agency.

We did not read the Vermont statute. 8 V.S.A. 4793(a) is named here on the strength of the Department's own citation inside the consent order. Its text was not read at any source, and Vermont carries this page's largest dollar figure.

Currency evidence is thin for the two strongest legal claims here. The New York Senate's page for Insurance Law 2101 offers only "most recent revision (from 2014-10-03)," and Cornell's reproduction of 212 CMR gives no version date at all beyond a note that state regulations are updated quarterly. Both were read on 2026-09-01, and neither carried a dated currency warranty of the kind FindLaw gives the Pennsylvania section ("Current as of January 01, 2026") or the eCFR gives the federal regulation ("up to date as of 8/28/2026").

No national enforcement count was located. There is no public aggregate of actions for unlicensed adjusting or appraising that this research could reach. The NAIC's regulatory information retrieval system is not public, and Pennsylvania's enforcement search offers no programmatic access. Delaware's three examinations are a base rate for one state, not a national one.

We did not establish what most appraiser examinations test. Repair knowledge is verified only for Massachusetts. Connecticut, Rhode Island and North Carolina require the licence; whether their examinations test collision repair competence is unknown, and Connecticut permits the examination to be waived for qualifying nonresidents.

No regulator has been found enforcing an appraiser licensing rule against an automated estimating system. New York's "directly supervises the writing of" is the obvious statutory hook, and no enforcement action applying it to software was located. Massachusetts forecloses photo-only appraisal through the personal inspection rule, not through any instrument aimed at the technology.

Delaware's appraiser position is unresolved. Delaware licenses adjusters and checks them on examination. The provision that formerly regulated appraisers separately, 18 Del. C. 1722, "Regulation of adjusters and appraisers", is repealed, and what if anything replaced it was not established.

We are not saying anything about who reviewed any particular photo estimate. No carrier page examined here discloses whether a licensed adjuster, a licensed appraiser or an automated system reviews submitted photographs. That opacity is itself the finding, and it is what a state with an appraiser licence is in a position to ask about and a state without one is not.

Corrections

2026-09-02, the Delaware comparison, narrowed after publication. This page shipped saying the three Delaware examinations were "same regulator, same licensing requirement, same examination programme, three answers", and noting that the zero came from a random sample. A later research pass went back to the three reports and measured something the page had asserted rather than checked: only the State Farm report describes how the examiners tested. Its phrases "randomly selected adjusters" and "verify their licensing", and its request for a list of licensed adjusters, appear in that report and in neither of the other two, on a string search whose positive control confirms the word "adjuster" itself appears four times in the GEICO report. The section above now says so. The comparison still stands and it is still the most honest evidence on this page; it is narrower than the version published yesterday, because three examinations under one statute is what the documents establish and three runs of an identical test is not. Nothing else on the page rests on the difference.

This page is new. The entries below are corrections made to its own draft before publication, by an adversarial pass in which every source was re-pulled and every quotation string matched when it was read on 2026-09-01. A page that only shows its wins is not evidence of anything, so the draft's errors are published with it, including the ones that would have damaged a named company.

2026-09-01, Vermont consent order against Allstate. The draft said the Department of Financial Regulation "found Allstate in violation" of 8 V.S.A. 4793(a) and reported the $225,000 penalty without the document's own no-admission language. That is defamation by implication: a negotiated stipulation is not a finding of fact against a company. It now reads that the Department concluded Allstate violated the section in a stipulation in which Allstate agreed to resolve the matter without a hearing and "do[es] not admit the existence of violations as set forth in this agreement," with the no-admission clause in the same sentence as the conclusion, and the sentence "No court has ruled on the conduct" beside it.

2026-09-01, Delaware State Farm quotation. The draft rendered the examination report's sentence as "using the verification service from the Department." The report says "utilizing." The altered word sat inside quotation marks, in the passage this page relies on most heavily, and about a named carrier's clean result. Corrected to the report's own word.

2026-09-01, GEICO examination period. The draft gave the GEICO Delaware examination period as 1 January 2020 to 31 December 2023. That is the underwriting and rating period. The claims review, which is where the licensing finding sits, ran 1 January 2021 to 31 December 2023. The section compares periods across three carriers, so the wrong window made the comparison wrong. Corrected and labelled "claims examination period."

2026-09-01, Pennsylvania Allstate violation count. The draft said that consent order yields "a stated total and a per-category breakdown" of 861(b) violations. It states no total, and successive reads of it did not agree on a count. The claim was cut rather than softened: no violation count for that order is published on this page, and the order is now cited by docket, date, penalty and URL so anyone can check it. The draft had also named the carrier and described violations with no citation at all.

2026-09-01, a national claim this research cannot support. The draft said Pennsylvania audits the identity of the person who wrote the estimate, "which most states do not." Nothing in this research establishes what most states do, and the limitations section of the same page disclaims exactly that. It now reads "which no other state examined here was found to do."

2026-09-01, the Bureau of Labor Statistics projection. The draft said employment of auto damage appraisers is projected to fall 6 percent. The live page, last modified 27 August 2026, says 9 percent. Corrected. In the same pass the NAIC survey citation was found to be a dead link, double-encoded and pointing at the wrong directory; it was repointed to the working URL and all five figures quoted from it were re-verified there.

Related

• The rate loop: how the prevailing labour rate is set
• What the Allstate McKinsey and Colossus records actually say
• Who is allowed to set your claim number
• Adjuster scorecards and the personal licence

Sources

• New York Insurance Law 2101, the state legislature's own text of the definitions section, carrying the adjuster exemptions at (g)(1) and the auto body repair estimator definition at (j). It is the source of the "unless acting as an auto body repair estimator" carve-out and of "who writes, or who directly supervises the writing of." Read on 2026-09-01.
• Texas Insurance Code chapter 4101, the state's own statute site, for the licensing requirement at 4101.051, the salaried employee exemption at 4101.002(a)(2), the technical assistance exemption naming the estimator and the photographer at 4101.002(a)(3), and the penalty at 4101.203. Read on 2026-09-01.
• 212 CMR 2.02, a reproduction of the Massachusetts appraiser licensing regulation, for the sentence barring any unlicensed person from appraising or estimating motor vehicle damage. Cornell is a republisher, not the issuing agency. Read on 2026-09-01.
• 212 CMR 2.04, the same reproduction, for the personal inspection duty, the photograph requirement and the $1,500 net of deductible exclusion. Read on 2026-09-01.
• M.G.L. c. 26 section 8G, a reproduction of the Massachusetts statute creating the Auto Damage Appraiser Licensing Board, for the board's composition, the applicant qualifications and the sworn appraisal requirements. Read on 2026-09-01.
• 63 P.S. 861, a reproduction of the Pennsylvania Motor Vehicle Physical Damage Appraiser Act provision requiring the appraiser's licence number and an itemised listing of damages on the face of the appraisal. The page states it is current as of January 01, 2026. Read on 2026-09-01.
• Conn. Gen. Stat. 38a-790, a reproduction of the Connecticut motor vehicle physical damage appraiser licensing section, including the clause permitting the Commissioner to waive the examination for a qualifying nonresident. Read on 2026-09-01.
• R.I. Gen. Laws 27-10.1-1, a reproduction of the Rhode Island appraiser licensing requirement, cited here for its near-identical language to Connecticut's. Read on 2026-09-01.
• N.C.G.S. 58-33-26, a reproduction of the North Carolina licensing section naming the motor vehicle damage appraiser as a licensed category alongside the producer and the adjuster. Read on 2026-09-01.
• Fla. Stat. 626.112, a reproduction of the Florida statute barring unlicensed insurance adjusting at (1)(a) and grading knowing violations of the section as a third-degree felony. Read on 2026-09-01.
• Fla. Stat. 626.874, a reproduction of the Florida emergency adjuster provision, for the eligibility language and the carrier certification mechanism. Read on 2026-09-01.
• 18 Del. C. chapter 17, a reproduction of the Delaware licensing chapter, for section 1703 and for the repealed status of section 1722, "Regulation of adjusters and appraisers." Read on 2026-09-01.
• Delaware market conduct examination, Travelers, the Insurance Department's own report for 1 January 2020 to 31 December 2022, the source of the sixteen unlicensed adjusters finding and of the recommendation that closed it. Read on 2026-09-01.
• Delaware market conduct examination, GEICO, the Insurance Department's own report covering seven GEICO entities, claims period 1 January 2021 to 31 December 2023, the source of the three unlicensed adjusters finding. Read on 2026-09-01.
• Delaware market conduct examination, State Farm, the Insurance Department's own report for 1 January 2017 to 31 March 2022, the source of the random-sample licensing check and of "No exceptions were noted." Read on 2026-09-01.
• Vermont DFR docket 21-024-I, the Department of Financial Regulation's stipulation and consent order of 8 December 2021, the source of the 8 V.S.A. 4793(a) conclusion, the $225,000 penalty and the no-admission clause quoted beside it. Read on 2026-09-01.
• Pennsylvania market conduct examination MC24-12-031, State Farm Mutual Automobile, ordered 16 January 2025, the source of the $55,000 penalty and of the 861(b) violations itemised by claim category. It records no unlicensed appraiser finding. Read on 2026-09-01.
• Pennsylvania consent order MC25-09-006, Allstate Fire and Casualty, ordered 4 November 2025 for calendar year 2023, the source of the $5,000 penalty and of the missing appraiser licence number violations. It states no consolidated violation count, and none is published here. Read on 2026-09-01.
• ADALB repeal of Advisory Ruling 2014-01, the Massachusetts board's own document recording the majority vote of 21 July 2015 and the warning about fines and penalties. It gives no reasons. Read on 2026-09-01.
• 29 C.F.R. 541.203(a), the eCFR, for the federal duties list assuming the adjuster inspects the damage and prepares the estimate. The page states it is up to date as of 8/28/2026. Read on 2026-09-01.
• Roe-Midgett v. CC Services, the Seventh Circuit decision affirming judgment for the employer, the source of "tools that channel rather than eliminate the MDAs' discretion" and of the $12,000 settlement authority. Read on 2026-09-01.
• Robinson-Smith v. GEICO, the D.C. Circuit decision reversing for GEICO, the source of the claim volume, the settlement authority levels and the post-payment review description. Read on 2026-09-01.
• In re Farmers Insurance Exchange Claims Representatives' Overtime Pay Litigation, the Ninth Circuit decision reversing the approximately $52.5 million award to 1,039 adjusters and holding them exempt. Read on 2026-09-01.
• Bureau of Labor Statistics Occupational Outlook Handbook, for the 13,500 auto damage appraiser count, the 9 percent projected decline over 2025 to 2035, and the sentence about working under the company licence. Read on 2026-09-01.
• NAIC private passenger auto survey team report, reported December 2022, the source of the 55 and 50 company counts, the zero for claim denial, and the 72 percent and 80 percent third-party model figures. Read on 2026-09-01.
• MassBay Community College auto damage appraiser programme, the college's own page, for the curriculum quotation, the two-part structure matching the state examination and the three-month apprenticeship letter. Read on 2026-09-01.
• WebCE adjuster licensing information, the industry list of sixteen jurisdictions said not to license adjusters. It is cited here as the object of the argument, not as authority. It carries no date and makes no reference to auto damage appraiser licensing. Read on 2026-09-01.
• Commissioner's Bulletin B-0003-26, third-party copy, a law firm's hosted copy of the Texas Department of Insurance bulletin dated 12 June 2026, used because the issuing agency was unreachable. Read on 2026-09-01.

Every URL above was fetched and its HTTP status recorded when it was read on 2026-09-01, and every quotation on this page was re-pulled from the source named beside it and string matched against the document before publication. Where a passage would not re-verify it was cut rather than softened, and the cuts are recorded above in Corrections and in what we could not establish. One host could not be reached at all: tdi.texas.gov returned HTTP 500 to every request, across two URL forms and a re-check on the publication date, with its robots file timing out, so the Texas bulletin is quoted from the third-party copy named above and is flagged twice on this page as unconfirmed against the issuing agency. Direct command-line fetching was refused at the network gateway for every host, so all retrieval ran through fetching services, and quoted strings were re-queried as exact-match questions rather than accepted from any paraphrase. Justia, FindLaw and Cornell are commercial reproductions of primary text rather than issuing agencies, and are labelled as such above. This page describes licensing law, it is not legal advice, and this page makes no claim to be a national map of who may write an estimate.

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

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