Roofing Insurance Laws in Michigan

Informational only — not legal advice. Laws and case precedent change, and outcomes depend on your specific policy language. Verify current law with your state Department of Insurance or a qualified attorney before relying on it.

Can insurers depreciate labor when calculating ACV?

Prohibited

Michigan's insurance regulator does not permit carriers to depreciate labor as part of the standard actual cash value calculation on personal lines homeowners and dwelling claims. Labor may be depreciated only under a standalone, optional, separately priced endorsement that names the nontangible items and has prior DIFS approval, on policies issued or renewed effective July 1, 2025 or later. If your ACV statement shows depreciated labor and no such endorsement is on the policy, that depreciation does not belong there.

Authority

DIFS Bulletin 2024-26-INS (Nov. 8, 2024), which superseded Bulletin 2024-18-INS, defines "nontangible items" as labor, taxes, fees, and overhead and profit, and bars depreciation of those items in the standard ACV definition absent an approved optional endorsement. The bulletin rests on MCL 500.2236(5), which prohibits forms containing inconsistent, ambiguous, or misleading clauses. One qualification: this is agency interpretive guidance grounded in a general anti-misleading-forms statute, not a promulgated administrative rule.

DIFS Bulletin 2024-26-INS (official PDF, michigan.gov) — verified directly · DIFS press release announcing insurer requirements (michigan.gov)

Must insurers replace undamaged materials so the repair matches?

Unsettled

Michigan has no matching statute, regulation, or bulletin. Nothing requires a carrier to replace undamaged slopes or siding so the finished job looks uniform. Whether matching is owed turns entirely on the policy's own wording, typically "like kind and quality" or "comparable material and quality."

Authority

MCL 500.2026, Michigan's unfair claims settlement practices statute, lists prohibited practices (a) through (n); none contains the NAIC reasonably-uniform-appearance or line-of-sight language. Nothing elsewhere in Insurance Code Chapter 500 addresses matching, and no DIFS bulletin adopts it. No Michigan Supreme Court or Court of Appeals decision establishes a matching obligation. The only Michigan-specific ruling is Bernert v. State Farm Fire & Cas. Co., No. 10-12359, 2012 WL 1060089 (E.D. Mich. Mar. 29, 2012), which read a common construction provision to require no matching. It is a non-binding federal trial court decision about teak floors and a plaster ceiling, not a roof.

MCL 500.2026 Michigan unfair claims settlement practices statute, no matching requirement (Michigan Legislature, primary) · Michigan Compiled Laws Chapter 500 Insurance Code index, no matching provision (Michigan Legislature, primary) · Michigan DIFS Bulletins index, no matching bulletin (agency)

Can a contractor pay or waive the homeowner's deductible?

No specific statute

Michigan has no deductible-specific law. No statute prohibits a contractor from absorbing, discounting, or covering a homeowner's deductible, and no statute separately bans advertising "we'll cover your deductible," "no out-of-pocket cost," or "free roof." The exposure is fraud, and it is conditional on the billing: the wrong is submitting an estimate for a price you never intend to collect, because the claim then misstates what the job actually costs.

You may

Bill the carrier the price you actually charge and collect it in full
Offer a payment plan or financing so the homeowner pays the deductible over time
Give a genuine, disclosed discount, with the estimate written at the discounted price
Absorb a deductible out of profit where the estimate to the carrier is still accurate
Explain to the homeowner that a real discount reduces what the carrier pays proportionally

You may not

Submit an estimate at a price you never intend to collect
Inflate the scope or line items to recoup the deductible from the carrier
Add phantom work or fake line items to offset the waived amount
Keep two sets of numbers, one for the carrier and one for the homeowner
Certify to the carrier that the deductible was collected when it was not

Penalty: A false or inflated claim is a felony punishable by up to 4 years and $50,000, up to 10 years if committed by conspiracy or agreement, plus mandatory restitution.

Authority

No deductible-specific statute exists in Michigan. The Insurance Code's anti-rebating provision, MCL 500.2066, reaches insurers, agents, and solicitors, not contractors, and is off point. The operative authority is the general insurance fraud chapter. MCL 500.4503 defines a fraudulent insurance act to include presenting a claim for payment under an insurance policy knowing the statement contains false information material to the claim. MCL 500.4511 sets the felony penalty at up to 4 years and $50,000, up to 10 years for conspiracy, with restitution.

MCL 500.4503 - Fraudulent insurance acts (Michigan Legislature) · MCL 500.4511 - Violation as felony; penalty; conspiracy; restitution (Michigan Legislature) · MCL 500.2066 - Rebating (applies to insurers/agents/solicitors, not contractors) · Chapter 45 Insurance Fraud (500.4501-500.4511), Insurance Code of 1956 - full chapter PDF (Michigan Legislature)

Can a contractor negotiate the homeowner's claim?

Restricted

Michigan has no roofing-specific claims statute, but it licenses adjusters, and it is unlawful to adjust a loss under an insurance policy, or hold yourself out as an adjuster, without a license. You may bid the job, write and submit your own estimate or supplement, document the damage, and discuss your scope, line items, and price with the carrier's adjuster. That is pricing construction. What you may not do is work the homeowner's claim for them.

You may

Inspect and document the damage
Prepare and submit your estimate or supplement for your own work
Discuss your scope, line items, and pricing with the carrier's adjuster
Meet the adjuster on site and walk the roof
Recommend that the homeowner file a claim
Explain your own numbers to the homeowner

You may not

Negotiate the settlement on the homeowner's behalf
Act as the homeowner's representative on the claim
Advise on policy coverage, exclusions, or claim rights
Advertise that you handle claims or deal with the insurance company for the homeowner
Take an assignment or power of attorney to work the claim
Hold an adjuster license while connected to a fire repair contractor

Penalty: DIFS may issue a cease-and-desist and impose civil fines of up to $1,000 per violation, up to $5,000 per violation where the person knew or should have known, capped at $50,000 in the aggregate, plus restitution and license suspension or revocation.

Authority

MCL 500.1222(1): "A person shall not adjust loss or damage under a policy of insurance or advertise, solicit business, or hold himself or herself out to the public as an adjuster unless he or she is licensed as an adjuster." The five exemptions at sec. 1222(2)(a)-(e) cover attorneys, marine average adjusters, insurer employees, producers with claim authority, and claims data-entry clerks. Contractors are not among them. Licensing is not a workaround for fire restoration work. MCL 500.1224(4) bars the commissioner from issuing an adjuster license to a person employed by, owning stock in, an officer or director of, or otherwise connected with a fire repair contractor. An adjuster for the insured is also capped at a 10% fee, must use a commissioner-approved written contract, may not pay unlicensed persons to help solicit or adjust a loss (MCL 500.1226), and may not collect a fee from a repair contractor for obtaining repair work (MCL 500.1227(2)). DIFS applied these in In re Aleksandr Guldshtadt, Enf. Case No. 25-18350 (Final Decision Apr. 1, 2026): a licensed adjuster for the insured who was also CEO of a restoration contractor drew a $50,000 fine and license revocation for, among other things, maintaining a financial interest in a fire repair contractor. Enforcement is administrative and civil under MCL 500.251(1)(b) and MCL 500.1244(1), not criminal. One qualification, and it matters. Chapter 12 nowhere defines "adjuster" or "adjust loss or damage"; MCL 500.1201's definitions reach agent, producer, negotiate, sell, and solicit, but not adjusting. There is no express contractor bar and no definition that plainly captures a roofer, so the limit on contractor conduct is drawn from the bare operative phrase in sec. 1222(1). The residential builder provisions at MCL 339.2411 are silent on insurance claims.

MCL 500.1222 — Adjuster's license required; exemptions (Michigan Legislature, official MCL text) · MCL 500.1224 — Adjuster license; sec. 1224(4) bars license to anyone connected with a fire repair contractor · MCL 500.1226 — Adjuster for the insured: no unlicensed helpers, 10% fee cap, approved written contract · MCL 500.1227 — Conduct of adjuster; no fee from a repair contractor for obtaining repair work · MCL 500.1201 — Chapter 12 definitions (documents the absence of any definition of "adjuster" or "adjust loss or damage") · MCL 500.251 — Cease and desist order; sec. 251(1)(b) acting as an adjuster without a license · MCL 500.1244 — Violation of chapter; civil fines ($1,000/$5,000 per violation, $50,000 cap), restitution, license revocation · MCL 339.2411 — Occupational Code art. 24, residential builders: complaints and prohibited conduct (silent on insurance-claim negotiation) · Michigan DIFS — Conflicting Employment Prohibited (adjuster license vs. fire repair contractor) · Michigan DIFS — Adjuster for the Insured Contract (public adjuster contract approval requirement) · DIFS Final Decision, In re Aleksandr Guldshtadt, Enf. Case No. 25-18350 (Apr. 1, 2026) — $50,000 fine, license revoked

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