Can your insurance company make you use its repair shop? What statutes and regulator rules in 20 states say

Eight states bar an insurer from requiring a particular repair shop in statute text: Arizona, California, Connecticut, Minnesota, Nebraska, New Hampshire, New York and Texas. Four more restrain steering through a regulator’s rule or the insurance department’s own consumer guidance. The other eight of the 20 states checked state no right to choose for body repairs: six regulate the shop the insurer itself designates when it elects to repair your car, one protects a direction to pay the shop you pick, and one covers glass only.

Choosing the shop is not the same as having the bill paid in full. In a hypothetical repair, the same damage costs $3,376 at the insurer’s designated shop and $4,238 at an independent shop with a higher labor rate and an original-equipment hood. The $862 gap falls on the insurer, on you, or on both, depending on which state’s rule is in play, and in a state with no rule on point it falls where the insurer’s estimate puts it.

Estimates and published averages, not a quote. Not insurance advice. State rules and insurer rules vary. Confirm requirements with your state insurance regulator or a licensed agent in your state.

Steering comes in three forms, and statutes treat each one differently

Insurers influence where a car gets repaired in three ways. They can require a shop, by making payment depend on it. They can recommend one, by offering a name or a list. And they can induce, by attaching a benefit to the choice. The statutes below tackle these in different combinations, which is why a page that says an insurer “cannot make you” use a shop without naming the state is not much help.

Requiring is the form every state in the first group bars. Recommending is where the rules split. New York says an insurer shall not recommend or suggest a shop unless the insured expressly asks. Pennsylvania lets an insurer give the names of two or more conveniently located shops only “upon his unsolicited request” from the claimant. Arizona, by contrast, allows the recommendation but demands that the insurer tell the person of the right to choose at the same moment it makes it. Inducing is addressed in Minnesota, where the unfair practice list reaches “any act or practice of intimidation, coercion, threat, incentive, or inducement” to use a particular shop, while saying that consumer benefits inside preferred vendor programs are not an incentive or inducement. Connecticut goes after a quieter form: an insurer, agent or adjuster may not state that choosing a shop outside the insurer’s repair program will cause delays or a lack of guarantee on the work.

A fourth thing sits underneath all three and is the part most people meet first: the price. Nobody has to be steered for a dispute to arise, because an insurer pays what its estimate says the repair costs. A shop of your choosing may write a higher number, and the rules that decide who carries the difference are separate from the rules on choice.

Twenty states, sorted by what the official text says

A statute that says an insurer may not require a particular shop is sorted apart from a regulator rule that only limits travel to a recommended shop, and apart from guidance on an insurance department’s web page, which explains the rules without being one. Each row gives who the text reaches and what the section says about enforcement, because those two cells decide what a reader can actually do with the right.

Three patterns in the table matter more than the state count. The first is that the strongest wording is statutory and the weakest is the regulator’s. Eight statutes address the right to choose in words an ordinary reader can follow, while the Pennsylvania, Virginia, Missouri, Ohio, Kentucky, Illinois and Washington rules never say a claimant may choose; they say what the insurer must do when it sends the car somewhere. It reflects how those rules are built: a duty to stand behind the shop the insurer designates, plus a limit on how far it can send you.

The second pattern is enforcement. Arizona says in the same section that it creates no private right or cause of action. Nebraska and Rhode Island make an act an unfair claims settlement practice only when it is committed flagrantly and in conscious disregard of the Act, or with a frequency that indicates a general business practice. Virginia’s statute uses the frequency test. A single steered claim is therefore usually a complaint to the insurance department, which can look at the insurer’s pattern, not a lawsuit. Texas is the one state in the table whose statute gives a named route: a written, documented complaint to the Department of Insurance by a beneficiary, a third-party claimant or the shop itself.

The third pattern is who is covered. New Hampshire’s paragraph protects “any insured person or entity under that policy,” so on its face it protects first-party claims. California defines the claimant to include a third-party claimant who asserts a right of recovery for repairs under an insurance policy, and Texas bars an insurer from requiring a third-party claimant to use a particular shop. Anyone who was hit by another driver should read the “Who it reaches” cell for their state before assuming the right to choose carries over.

Silence is the easiest thing to get wrong in this table, because the same state can have a general claims rule that says nothing about shops and an automobile rule that does. Virginia’s 14VAC5-400-70 has no shop language, and 14VAC5-400-80, the next rule, does; Virginia’s unfair claim practices statute says nothing on shop choice and mentions repair facilities only for kickbacks, rebates, repair-facility appraisals and after-market part estimates, including a bar on a kickback or rebate between an insurer and a repair facility in connection with an appraisal service. Pennsylvania has the same split between 31 Pa. Code 146.7, which has none, and 146.8, which does. A claim that a state has no rule should name the section it relies on.

Washington deserves a note because the text changed this autumn. A rule filed in August 2026 as WSR 26-17-089 replaced the older version of WAC 284-30-390 effective October 18, 2026. It speaks throughout of “the repair facility chosen by the claimant,” bars requiring a claimant to travel unreasonably to have the car repaired at a specific facility, and requires the insurer to disclose its reasons if it pays less than the estimate from the claimant’s chosen facility. WAC 284-30-330, the general list of unfair claim practices, is silent on shop choice.

Where the insurer may still pick the shop: the election to repair

Six rows in the table sit in the middle group, and they describe the real exception to the right to choose. Florida’s statute speaks of an insurer that “elects to repair a motor vehicle and specifically requires a particular repair shop.” Virginia and Missouri speak of an insurer that “elects to repair” and has the car repaired at a shop it designates. Ohio and Kentucky speak of an insurer that designates a specific shop or one or two shops. Washington speaks of an insurer that, “if provided for by the terms of the applicable insurance policy,” elects to exercise its right to repair the loss vehicle at a specific repair facility. New Jersey requires the election to be in writing, with a reasonable estimate of how long the repair will take.

None of those sentences says the insurer may do this in every case. Each assumes a policy that gives the insurer a right to repair or replace instead of paying cash, and attaches duties to the exercise of that right. Your own policy’s loss settlement section is where to find out whether that language exists. If it does, the insurer is not steering in the sense the first group of statutes forbids; it is choosing to perform the repair itself, through a shop it picks, and the state rule then decides what it owes you.

The duties follow a consistent shape. The car must be restored to its condition before the loss. In Florida the standard is “performance and appearance immediately prior to the loss”; in Virginia, Missouri and Ohio it is “condition prior to the loss.” The claimant bears no added cost beyond what the policy states. In Virginia, Missouri and Ohio the repair must also be completed within a reasonable period. New Jersey spells out more: when the car is repaired at a facility the insurer names for its own estimated sum, the insurer must select a facility that issues written guarantees that its work meets generally accepted standards for safe and proper repairs, and must cause the vehicle to be restored at no additional cost, within a reasonable time, if the facility does not repair it to those standards. If the insurer elects to physically take the vehicle and have it repaired, New Jersey also requires the insurer to guarantee the work in writing.

The practical point is about who answers for a bad repair. If you accept the insurer’s designated shop and the paint peels or a panel gap is wrong, in these states the insurer owes the fix, because it elected the repair and chose the shop. The cited rules attach the restoration duty to the insurer when it designates the shop, or when its recommendation is accepted. That is the trade built into them: the insurer takes on the quality risk, and the repair is done at the price it set. California puts the same trade on paper when an insurer’s recommendation is accepted: it must cause the vehicle to be restored to its condition before the loss at no additional cost beyond the policy, and an oral recommendation that is accepted triggers a written notice within five calendar days.

Kentucky’s version is a useful check on how thin the guarantee can be. When the insurer designates only one or two shops, it must “assure that the repairs are performed in a workmanlike manner.” The rule does not say what remedy follows, and it names no deadline. The timeline for how long a repair claim may take in each state is a separate question, covered in the claim timeline by state guide. A shop choice can also lengthen the rental period, since a booked-up shop adds days; the loss of use guide explains why days lost to a long wait you chose are the days most open to challenge when another driver’s insurer is paying.

What the insurer has to say when it names a shop

Where the right to choose is written down, so is a duty to tell you about it. The notice rules differ in timing and in wording, and the wording is worth reading because an adjuster’s improvised version rarely matches it.

Look at what is absent from these notices. None of them promises that the insurer will pay whatever the shop you choose bills. California’s statutory statement promises restoration at no added cost only if you use the recommended shop. Minnesota’s advisory promises coverage of “the reasonable costs of repairing your vehicle to its pre-accident condition no matter where you have repairs made,” which is the strongest wording in the group and turns the dispute into a question of what counts as reasonable. Connecticut’s and New York’s notices state a right to choose without addressing price at all. Illinois’s Department says it in one sentence: you are not required to use the suggested shop, but if your shop charges more, you may have to pay the difference.

Texas adds two protections that other states leave out. A contract between an insurer and a repair shop, including a discount agreement the shop gives in exchange for referrals, may not result in a reduction of coverage under the insured’s policy. And an insurer may not prohibit a shop from telling a beneficiary or third-party claimant the description and source of the parts used and the amounts charged to the insurer for parts and related labor. Ask the shop for that information in writing; in Texas it is protected.

The same repair at two shops: $862, and the rule that decides who carries it

Benchmark, not a quote. Every dollar figure here is a hypothetical input, not a published average and not a price any shop will charge, and the example is not insurance advice. The inputs are chosen to show the arithmetic of how a state rule moves money between a claimant and an insurer. Replace each with the numbers on your own estimates.

The case is a front-corner collision claim with a $500 deductible. The damage needs a fender ($620), a headlamp assembly ($540), and a hood, plus 14.0 body labor hours and 6.5 refinish hours, 20.5 hours in all. Paint and materials are priced at $38 per refinish hour, or $247. The insurer’s estimate assumes a non-original hood at $780 and a labor rate of $58 an hour. The independent shop writes an original-equipment hood at $1,150 and a labor rate of $82 an hour.

On those inputs the insurer’s estimate is parts of $1,940 ($620 + $540 + $780), labor of $1,189 (20.5 hours at $58) and materials of $247, for $3,376. The independent shop’s estimate is parts of $2,310 ($620 + $540 + $1,150), labor of $1,681 (20.5 hours at $82) and the same $247, for $4,238. The gap is $862, and it has two separate causes: $492 is the labor rate (20.5 hours times $24), and $370 is the hood ($1,150 minus $780). Which of the two a rule reaches decides the outcome.

Four of the rows end at the same number, $1,362, and they show the point of the exercise. The insurer’s own estimate is the default anchor. A rule that grants the right to choose does not by itself move that anchor; a rule that deals with price does. Nebraska’s cap moves it down to the lowest estimate for like kind and quality. New Hampshire moves it to the price available from “a recognized, competent and conveniently located, independent repair shop or facility which is willing and able to repair the damaged automobile within a reasonable time,” which is why the $82 rate matters in that row. The Illinois, Kentucky and Ohio rule is binary, and that is what makes it useful: the insurer must either pay the difference or find a shop that will do the work at its number.

The arithmetic also shows why the labor rate and the parts line need separate treatment. Of the $862, $492 is labor rate and $370 is the hood. A claimant who wins the hood argument in a state that treats parts strictly, and loses the labor argument, still pays $492 above the designated-shop case. A claimant who wins labor and loses the hood pays $370. Anyone arguing a gap should say in writing which of the two they are disputing and attach the shop’s invoice lines, because an adjuster who is told only that the estimate is too low has nothing to answer.

One more check belongs in the file. Missouri’s rule bars using, as the basis for a cash settlement with a first-party claimant, an amount below what the insurer would pay if repairs were made, other than on a total loss, unless the insured agrees. If an adjuster offers a cash figure below the insurer’s own repair estimate, the Missouri rule treats that as a problem; the question to ask in any state is what repair estimate the cash figure is built from. Deductible mechanics, including when another driver’s insurer repays it, are in the deductible recovery guide.

Parts: Minnesota’s clause is stricter than the like-kind rules in the other states in the table

The $370 hood difference in the example is a parts dispute, and states answer it in three ways. The most common is a quality floor. Florida bars an insurer from requiring replacement parts that are not at least equivalent in kind and quality to the damaged parts in fit, appearance and performance. Kentucky and Illinois use the same idea for crash parts, with “fit, quality, and performance” as the test, and Illinois adds identification and like-kind-and-quality provisions of its own. North Carolina’s Department of Insurance says no insurer shall require after-market parts unless the part is equal to the original in fit, quality, performance and warranty. The Texas Department of Insurance says the insurer is only required to pay for parts of like kind and quality, and does not have to pay for original manufacturer parts.

Minnesota goes further in a single clause. The same sentence that bars requiring a particular shop bars requiring, as a condition of payment, that parts other than window glass be replaced with parts other than original equipment parts. It does not say an insurer may never write an estimate with non-original parts, but it does say the insurer cannot make that a condition of paying the claim. That is a different rule from a quality floor. Under a quality floor a non-original hood is acceptable if it matches in fit, appearance and performance. Under Minnesota’s clause the insurer cannot make it a condition of payment.

Texas sits between the two. Its statute says an insurer may not limit its coverage by specifying the brand, type, kind, age, vendor, supplier or condition of parts or products used to repair the vehicle, except as the commissioner’s rules provide. The Department’s consumer guide says like kind and quality is the measure. A reader in Texas who is offered a non-original hood should ask the adjuster which policy limitation, if any, the insurer relies on, and whether the written consent that the statute requires was given when the policy was bought.

Rhode Island’s rule alone reaches the labor and procedure side of parts. Its statute lists as unfair claims practices refusing to compensate a body shop for documented charges based on the current version of recognized paint and refinishing programs, discounting those charges by failing to use a program in its entirety, and refusing to compensate documented procedures that the manufacturer or a recognized repair program identifies as required or recommended. For a claimant, the practical effect is that a Rhode Island shop’s invoice lines can be defended by reference to named systems instead of by argument. These Rhode Island provisions, like its direction-to-pay rule, turn on the frequency test in 27-9.1-3.

Glass is handled separately in four of the twenty states: Arizona, New York, Montana and Minnesota

Four of the twenty states treat a cracked windshield apart from a collision repair, and the separation cuts both ways. Arizona’s right to choose any repair facility applies to repair facilities “other than glass repair facilities.” New York exempts glass-only claims from the duties not to recommend a shop and to print the notice. Montana’s only section in the table is about glass: an insurer may give a list of nearby providers if some are reasonably close, the insured may use an unlisted provider, and the insurer may require up to three competitive bids if the insured does not use the list.

Other states give glass its own protection that collision repair does not get. Minnesota’s list has three glass clauses of its own, including an advisory that begins “Minnesota law gives you the right to go to any glass vendor you choose,” and one that treats a warranty as something other than an inducement. Nebraska and Connecticut write glass into the same clause as other repair. New Hampshire’s paragraph also covers glass replacement. A reader who sees “repair shop” in one state’s statute and “glass company” in another’s should check which kind of claim is meant. The windshield replacement guide works through the three states with dedicated glass statutes, the camera calibration problem, and the comprehensive-versus-collision question that decides whether a glass claim costs a deductible.

When the other driver’s insurer is paying

Many people who search this question were not at fault. They are third-party claimants, with a claim against someone else’s liability policy, and the statutes above treat them unevenly. California’s definition expressly includes a third-party claimant who asserts a right of recovery for repairs, and Texas bars an insurer from requiring a third-party claimant to have repairs made by a particular person or facility. Arizona’s language reaches any person with a motor vehicle loss, Minnesota and Nebraska reach the claimant, and the Pennsylvania, Virginia, Missouri, Ohio and Washington rules speak of the claimant. Florida’s statute lets an insurer “identify options to a third-party claimant relative to the repair of his or her vehicle,” and makes an insurer that specifically requires a particular shop answerable to the third-party claimant for restoration at no added cost beyond the policy.

New Hampshire, Connecticut and New York are drafted around the insured. If you are the third party in one of those states, the statute’s text does not speak to you, and your position rests on the regulator’s general claim-practice rules and on the facts. That does not mean the other driver’s insurer can insist on its shop; it means the statute you would cite does not say so in terms. Ask the adjuster whether the insurer’s position is that you must use a specific shop, ask for it in writing, and keep the answer.

A third-party claim and a claim on your own collision coverage are two routes to the same repair. Using your own coverage means paying the deductible and letting your insurer pursue the other driver, and then every rule above is about your insurer. Using the other driver’s liability coverage avoids the deductible but leaves the shop and price disputes with an insurer you have no policy with. The guide to recovering your deductible and the one on filing the claim explain the sequence. For the difference between collision and comprehensive, which decides which deductible applies to which damage, see comprehensive vs collision coverage.

Direct payment and the check: who the money goes to

Choosing a shop often raises a second question: whether the insurer pays the shop or pays you. New Jersey answers it clearly. The insured has the right to receive the proceeds of any settlement, and the insurer “may not insist on making settlement proceeds jointly payable to the insured and the repair facility, or payable to the repair facility only.” The insured may elect, in writing, to have the insurer pay the repair facility directly to speed recovery. Rhode Island ties the same idea to its unfair claims list: an insurer that refuses to honor a signed direction to pay the repair benefit to the auto body shop of the consumer’s choice commits an unfair claims practice, subject to the frequency test.

A direction to pay moves the money; it does not settle the price. When the shop’s bill and the insurer’s estimate differ, read what the form says about who owes the difference between the insurer’s payment and the shop’s bill before you sign it, and keep a copy.

Supplements are the third place money moves. Repairs often reveal hidden damage after teardown. Washington’s new text requires the insurer to consider additional loss-related damage that the claimant or the claimant’s repair facility discovers after assessing the damage or during repairs, and to respond in writing to the claimant and the facility within five business days of receiving any supplemental estimate and the final invoice. Kentucky says the insurer’s estimate must be of an amount that allows repairs to be made in a workmanlike manner. A supplement request that arrives with photographs, an itemized line and a date is the document that triggers those duties.

Five moves that settle the shop question in writing

A claim goes better when the shop question is settled early and in writing. These moves apply in every state; the table shows how much weight each one has in yours.

1. Find out whether your policy gives the insurer a right to repair. The loss settlement section is the place. If it does, the insurer may be entitled to designate a shop, and the election-to-repair rules decide what it owes. If it does not, the choice of shop is yours and the dispute is only about price.
2. Name your shop before the adjuster names one. In Minnesota the insurer must stop trying to influence you once you have chosen. In California it may not suggest a different shop after you have chosen. In Arizona and New Hampshire it must tell you that you may use any other shop at the moment it offers a name.
3. Ask for the insurer’s estimate in writing and give it to your shop. Several rules require the insurer to supply the estimate it relies on, and the shop can write a supplement against it line by line. Ask the shop to separate its labor rate from its parts lines, so a disagreement has one cause at a time.
4. If the shop’s number is higher, ask the insurer for the rule’s own alternative. In Illinois, Kentucky and Ohio that means asking it either to pay the difference or to name a shop that will do the repair for its estimate. In Washington it means asking for the list of nearby facilities that will repair for the estimate. In Nebraska it means finding out what the lowest estimate for like kind and quality is.
5. Keep a log of every recommendation and the date. If an insurer pressures you, or says that using another shop will cause delays or void a guarantee, write down the words and the date, and send a written complaint to your state’s insurance department. In Texas the statute names that route; in Connecticut that exact statement is itself prohibited.

If the insurer declares the car a total loss, the shop question falls away and the valuation question takes over; the total loss settlement guide covers it. If a claim is denied outright, the written appeal and complaint route is in the claim denied guide. More guides on each stage of a claim are in the claims section.

Questions readers ask

Once the repair route is settled, the deductible you paid on it may be recoverable from the at-fault driver’s insurer; the recovery guide shows the share formulas and the timing.