On July 17, 2026, the State of Hawaii Department of Commerce and Consumer Affairs Insurance Division issued Memorandum 2026-5PC (the Memorandum) titled “Hawaii Pet Insurance” to “All Insurers Issuing Pet Insurance Products.” The Memorandum states that effective January 1, 2026, under Hawaii Act 79 (the Act), “pet insurance is now classified as property insurance.” Previously, pet insurance was customarily classified as marine and transportation insurance since no separate statutory classification existed in Hawaii. The Memorandum outlines that insurers are expected to review and revise the appropriate “forms, disclosures, marketing materials, underwriting practices, and administrative procedures” now found in Article 33 of the Hawaii Insurance Code governing pet insurance. While insurers are not required to refile pet insurance programs filed and accepted before January 1, 2026, “any subsequent filing that revises such a program, including amendments to forms, rates, or rules” must be submitted. The Memorandum specifies that such submissions can be made in the National Association of Insurance Commissioners’ (NAIC) System for Electronic Rate and Form Filing (SERFF) system. Insurers should use the 01.0003 Pet Insurance category within the Property TOI in SERFF. Additionally, insurers that were writing pet insurance under a certificate of authority classification of marine and transportation “must submit a Uniform Certificate of Authority Application (UCAA) Corporate Amendment Application to change the certificate of authority classification to property insurance (HRS §431:1-206).” These certificates should be submitted through the NAIC’s UCAA portal.
