Hawaii Reclassifies Pet Insurance: A Significant Regulatory Update

Hawaii's Department of Commerce and Consumer Affairs has introduced a crucial update to the regulatory classification of pet insurance. As announced by Insurance Commissioner Scott K. Saiki, Act 79, set to be enacted in 2025, will reclassify pet insurance from marine and transportation insurance to property insurance, due to the establishment of a specific classification statute.

Starting January 1, 2026, pet insurance carriers in Hawaii are required to adhere to the new legal guidelines outlined in HRS §§ 431:33-101 to -109. This shift necessitates a thorough review of existing documentation and marketing materials to ensure compliance with these regulatory compliance requirements.

The Division has clarified that pet insurance programs approved before the 2026 deadline will not need to be reclassified. However, any modifications, including changes to forms, rates, or underwriting rules, must be filed as a Property Type of Insurance under the 01.0003 Pet Insurance subtype within SERFF. Insurers currently categorized under Inland Marine must transition their filings to property insurance by December 31, 2026.

Additionally, insurers with a Hawaii certificate of authority under Marine and Transportation must apply through the NAIC’s UCAA portal to switch to Property Insurance classification. This regulatory update effectively concludes pet insurance's classification as inland marine, underscoring the importance of compliance with updated classification standards. Any inquiries concerning pet insurance can be directed to the state's Property and Casualty Filings Branch and Financial Surveillance and Examination Branch.