This is a tooltip for the edit command button
Fred E. Karlinsky, Esq.
(954) 768-8278
Christian Brito, Esq.
(954) 768-8279
Timothy F. Stanfield, Esq.
(850) 425-8547


At the Summer 2022 National Association of Insurance Commissioners (NAIC) Meeting in Portland, Oregon, the Executive (EX) Committee and Plenary voted to adopt the Pet Insurance Model Act (“model act”). The adoption of the model act concludes a process that began in 2019. Although the NAIC exhibits some of the characteristics of a regulatory agency, including being composed of insurance regulators from all 50 states, the District of Columbia and five (5) U.S. territories, it does not have authority to enact laws. The model act therefore simply provides a framework for states to adopt “as is”, modify, or ignore completely. Current regulation of pet insurance varies widely across the states and, because the model act is not currently a NAIC accreditation standard,[1]  the impact of this model act remains to be seen.


The process of developing the model act began in April 2019 when the Pet Insurance (C) Working Group was established by the Property and Casualty Insurance (C) Committee in response to the NAIC White Paper, A Regulator's Guide to Pet Insurance. From the review of the White Paper, it was determined a model act should be developed to create appropriate regulatory standards for the pet insurance industry. The first draft of the model act was presented in October 2019 and continued to be developed over the course of twenty-four (24) meetings with veterinarian representatives, consumer representatives and insurance industry members. During their meeting in July 2021, the Working Group officially voted to adopt the Pet Insurance Model Act which was then presented to the Property and Casualty Insurance (C) Committee. During the Spring 2022 National Meeting, the Property and Casualty Insurance (C) Committee determined the Pet Insurance (C) Working Group, although recently disbanded, needed to reconvene to conduct edits to the model act.

Why Create a Model Law for Pet Insurance?

In the 2021-2022 National Pet Owners Survey conducted by the American Pet Products Association (APPA), 70% of U.S. households reported owning a pet. Since 2001, consumer spending on pet medical care has risen significantly. With the increase in household pet ownership and rising costs, APPA reported an estimated $32.2 billion was spent on pet care in 2021 alone. According to the North American Pet Health Insurance Association, North America’s pet insurance sector exceeded $2.83 billion at the end of 2021 and industry growth more than doubled over the past four years since 2018. As the costs associated with owning a pet increase, more pet owners will likely turn to pet insurance to help offset unexpected costs.

Traditionally, pet insurance is similar to health insurance for humans and usually includes varying levels of coverage, deductibles, and payment limits. Additionally, most pet insurance policies exclude pre-existing conditions and hereditary or congenital conditions, and some may not accept pets after a certain age or have waiting periods before benefits begin. With the continued and increased use of pet insurance, the NAIC determined that there were gaps in current regulations governing pet insurance which should be addressed.

California’s Influence

California adopted the first pet insurance law in 2014. Because California is the only state in the nation to have a pet insurance law in place, the members of the Pet Insurance (C) Working Group based much of the new model act on California’s law. The existing law established essential consumer protections by requiring pet insurers to disclose information regarding reimbursement benefits, preexisting condition limits and provide clear explanation of the limits of coverage. Also included in the legislation was a “free look” period in which a consumer can return the policy within 30 days if it is not up to their satisfaction. The legislation was prompted by increasing amounts of complaints to the California Department of Insurance about confusing and misleading pet insurance policies. Over time, policyholders cited frustration that their pet insurance policy exclusions outweighed the benefits. Ultimately, consumers were not confident in the product they were buying, and California took steps to rectify the issues.

The NAIC determined that adopting a model act for states to adopt as best suits their needs would be the best way to address pet insurance issues nationally.  Subsequently, on January 1, 2023, Maine adopted the Pet Insurance Act, which is based, in part, on model language from the NAIC. No other states have announced adoption of the model act to date.  

Key Elements

The new model act establishes regulatory standards for the pet insurance industry. The key elements of the new model act include:

Consumer protections: The model act codifies consumer protections related to policy renewals, required disclosures of waiting periods, policy limits, exclusions, benefit schedules and more.

Regulations for preexisting conditions: The model act limits how insurers can deny pet insurance claims related to preexisting conditions of covered pets.

Wellness programs: The model act requires insurers and their producers to differentiate pet wellness programs from insurance policies. This aims to help eliminate consumer confusion between insurance policies and non-insurance wellness programs.

Training requirements: The model act ensures proper training requirements for insurance producers to ensure that they are appropriately preparing and presenting information to consumers.

The Future

Having finished its work in enacting the model act, the Pet Insurance (C) Working Group will not be reappointed. Given the special roles that pets play in our society, the rising costs associated with pet care, and the increased interest that pet insurance has garnered at the NAIC and within the insurance industry, individual state legislation in this space is likely. “This model law establishes clear rules for the sale of pet insurance and provides important disclosures to pet owners interested in purchasing this product,” Beth Dwyer, superintendent of insurance for the Rhode Island Department of Business Regulation, said in a release. “Now, it is up to the states to see if they would like to adopt or modify the model law for this regulatory framework to be in effect.” Indeed, the NAIC’s efforts to protect consumers and increase accountability in this growing space is important; however, it is now up to the states to determine on an individual basis exactly how pet insurance will be regulated going forward.


[1] An accreditation standard is a model that must be approved and adopted by all states for states to maintain their accreditation status with the NAIC. See Accreditation (