HI Commissioner's Memorandum 2026-5PC
Hawaii Pet Insurance
JOSH GREEN, M.D.
GOVERNOR | KE KIAʻĀINA
SYLVIA LUKE
LIEUTENANT GOVERNOR | KA HOPE KIAʻĀINA
STATE OF HAWAII | KA MOKUʻĀINA ʻO HAWAIʻI
DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS
KA ʻOIHANA PILI KĀLEPA
INSURANCE DIVISION
335 MERCHANT STREET, ROOM 213, HONOLULU, HAWAII 96813
P.O. BOX 3614, HONOLULU, HAWAII 96811
Phone Number: 1-844-808-DCCA (3222)
Fax Number: (808) 587-6714
cca.hawaii.gov/ins/
NADINE Y. ANDO
DIRECTOR | KA LUNA HOʻOKELE
SCOTT K. SAIKI
INSURANCE COMMISSIONER
July 17, 2026
MEMORANDUM 2026-5PC
To:
All Insurers Issuing Pet Insurance Products
From:
Scott K. Saiki, Insurance Commissioner
Subject:
Hawaii Pet Insurance
The purpose of this memorandum is to clarify that pursuant to Act 79 (SLH
2025), pet insurance is now classified as property insurance.1
Prior to the enactment of Act 79, Hawaii customarily classified and regulated pet
insurance products as marine and transportation insurance because there was no
statutory classification in place. However, Act 79 now makes clear that pet insurance is
considered “property insurance.” Act 79 defines “pet insurance” as “a property
insurance policy that provides coverage for accidents and illnesses of pets.” See HRS
§431:33-103 (emphasis added).2
Because Act 79 took effect on January 1, 2026, insurers providing pet insurance
in Hawaii are expected to review their forms, disclosures, marketing materials,
underwriting practices, and administrative procedures to ensure compliance with the
new statutory requirements found in HRS §§ 431:33-101 through -109.
To facilitate the transition, the Division will not require insurers to refile, solely for
reclassification purposes, pet insurance programs that were filed and accepted before
January 1, 2026.
1 Act 79 became effective on January 1, 2026.
2 Marine and transportation risk is inapplicable because it protects against loss of or damage to property
and financial interests while in transit, i.e., transportation risk. See HRS §431:1-207.
Any subsequent filing that revises such a program, including amendments to
forms, rates, or rules, should be submitted under the applicable Property Type of
Insurance (“TOI”) and pet insurance subtype designated in SERFF.
Insurers that are currently writing pet insurance under the Inland Marine TOI
should submit all future rate, rule, and form filings for those products under the 01.0003
Pet Insurance within Property TOI in SERFF.
Insurers that previously did not file their pet insurance products based upon an
interpretation of an Inland Marine exemption must file their pet insurance products
under the 01.0003 Pet Insurance within Property TOI in SERFF on or before December
31, 2026.
Existing insurers that are underwriting pet insurance only with a Hawaii certificate
of authority classification of HRS §431:1-207 (Marine and Transportation Insurance)
must submit a Uniform Certificate of Authority Application (“UCAA”) Corporate
Amendment Application to change the certificate of authority classification to HRS
§431:1-206 (Property Insurance). Submissions must be made through the National
Association of Insurance Commissioners’ UCAA portal.
To clarify, pet insurance products will no longer be classified as inland marine
insurance for regulatory purposes and insurers should not rely on inland marine-related
exemptions.
Questions may be directed as follows:
Pet Insurance Products
Grant Shintaku
Property and Casualty Filings Branch
insrpapc@dcca.hawaii.gov
UCAA and Certificate of
Glenn Yamashita
Authority Amendments
Financial Surveillance and Examination Branch
inscert@dcca.hawaii.gov.