HI| The Hawaii Insurance Division Memorandum 2026-5PC clarifies that, effective January 1, 2026, Hawaii law (Act 79, SLH 2025) now expressly classifies pet insurance as property insurance rather than marine and transportation, defining it as a property insurance policy covering pets’ accidents and illnesses and subjecting these products to the new requirements in HRS §§ 431:33-101 to -109.
- Insurers are expected to review and adjust forms, disclosures, marketing, underwriting, and procedures for compliance, but are not required to refile programs accepted before January 1, 2026 solely due to reclassification.
- Going forward, any revisions must be filed under the appropriate Property Type of Insurance and pet insurance subtype in SERFF, with insurers currently using Inland Marine TOI required to submit future filings under 01.0003 Pet Insurance within Property TOI and those relying on an Inland Marine exemption required to file these products under that TOI by December 31, 2026.
- Insurers with a Hawaii certificate of authority limited to marine and transportation (HRS §431:1-207) must file a UCAA Corporate Amendment via the NAIC UCAA portal to change their authority to property insurance (HRS §431:1-206), and are advised that inland marine classification and related exemptions may no longer be used for pet insurance, with product and UCAA questions directed to the indicated Insurance Division contacts.