Roofing Insurance Laws in Washington

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

Washington prohibits depreciating labor when a carrier calculates actual cash value on a first-party property claim. The expense of labor to repair, rebuild, or replace covered property is not a component of physical depreciation and may not be depreciated or subject to betterment. The only exception is intrinsic labor already built into the cost of manufactured materials, so a labor line depreciated on your roof estimate is improper and should be challenged.

Authority

WAC 284-20-010(4) provides that, except for intrinsic labor costs included in the cost of manufactured materials or goods, the expense of labor necessary to repair, rebuild, or replace covered property is not a component of physical depreciation and may not be subject to depreciation or betterment. The section governs basic fire insurance contracts, which by its own terms include homeowners and special multiperil policies. The subsection was adopted by Office of the Insurance Commissioner rulemaking, CR-103P final adoption, WSR 21-23-066, filed November 12, 2021, effective January 1, 2022.

WAC 284-20-010 (official Washington Administrative Code, leg.wa.gov) · WA OIC rulemaking CR-103P final adoption, WSR 21-23-066 (.gov PDF, amends WAC 284-20-010 effective Jan. 1, 2022) · WA OIC rulemaking R 2021-04 - Concise Explanatory Statement (.gov PDF)

Must insurers replace undamaged materials so the repair matches?

Unsettled

Washington has no matching, uniform-appearance, or line-of-sight requirement for first-party property claims. Whether a carrier must replace undamaged slopes or elevations to match turns on the policy wording, such as a promise to restore the property as near as practicable to its pre-loss condition. Argue matching from the policy language, not from state law.

Authority

Chapter 284-30 WAC is the Unfair Claims Settlement Practices Regulation. WAC 284-30-330, which defines specific unfair claims settlement practices, contains no matching or uniform-appearance provision. The chapter's only matching and betterment standards, WAC 284-30-390 and WAC 284-30-391, are limited by their terms to motor-vehicle claims. No Washington statute, insurance regulation, or controlling decision imposes a matching requirement on property claims. Pending OIC rulemaking R2025-05 would amend WAC 284-30-330, and the proposed amendments do not add a matching requirement.

Chapter 284-30 WAC (Unfair Claims Settlement Practices Regulation) — official WA Legislature code; index confirms no property-matching section · WAC 284-30-330 — Specific unfair claims settlement practices defined (verified: no matching/uniform-appearance/line-of-sight provision) · WAC 284-30-390 — Unfair settlement of motor-vehicle claims (verified: matching/betterment standards limited to motor vehicles) · WA OIC Rulemaking index — R2025-05 (minimum standards for claims handling), status proposed/not enacted

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

No specific statute

Washington has no statute barring a roofing contractor from paying, waiving, rebating, or absorbing a homeowner's insurance deductible, and no statute making the advertising of it a separate offense. The exposure is the billing. If you build the waived deductible back into an inflated estimate or invoice submitted to the carrier, the claim misstates what the job costs and that is insurance fraud, and a deceptive out-of-pocket promise can be an unfair or deceptive act under the Consumer Protection Act.

You may

Bill the carrier the price you actually charge and collect the deductible
Offer a payment plan or third-party financing for the deductible
Give a genuine, disclosed discount off your real price
Advertise pricing that reflects what you will actually invoice
Explain to the homeowner that the deductible is their share of the loss

You may not

Submit an estimate for a price you do not intend to collect
Inflate line items or quantities to absorb the deductible
Promise a free roof or no out-of-pocket cost the carrier is not funding
Rebate the deductible back to the homeowner after the carrier pays
Describe a discount to the carrier as the full contract price

Authority

Chapter 19.186 RCW governs roofing and siding contractors and salespersons. Its sections cover findings and intent at 19.186.005, definitions at .010, the written contract and rescission right at .020, the financing waiting period at .030, assignee liability at .040, Consumer Protection Act treatment at .050, and liability at .060. None addresses deductibles. The insurance code's rebating and inducement bans, RCW 48.30.140 and RCW 48.30.150, reach insurers, insurance producers, and title insurance agents, not contractors. RCW 48.30.133 is a $100 cap on gifts for the referral of insurance business by producers and does not apply to contractor deductible practices, notwithstanding sources that cite it that way. The general reach-throughs remain. A violation of the roofing chapter is a per se Consumer Protection Act violation under RCW 19.186.050, and Chapter 19.86 RCW reaches deceptive advertising independently. Knowingly inflating an estimate or invoice to recoup a waived deductible is insurance fraud.

RCW Chapter 19.186 (Roofing and Siding Contractors and Salespersons) — section index; no deductible provision (verified) · RCW 19.186.020 (roofing/siding written-contract requirements) — no insurance/deductible language · RCW 48.30.140 (Rebating—Other inducements) — binds insurers/producers, not contractors (verified) · RCW 48.30.150 (Illegal inducements) — insurer/producer inducement ban · RCW 48.30.133 (Gifts for referral of insurance business—Restrictions) — erroneously cited by some sources; not a contractor-deductible provision (verified)

Can a contractor negotiate the homeowner's claim?

Restricted

Washington licenses public adjusters and defines the role broadly enough to reach a roofer who takes over the homeowner's claim. You may work your own estimate; you may not work their claim. Write, submit, and defend your scope, supplement, and pricing, but leave settlement of the claim itself and any reading of the policy to the homeowner, their carrier, or a licensed adjuster.

You may

Prepare and submit your own estimate, scope, and supplement
Document the loss with photos and measurements
Meet the adjuster on the roof and walk the damage
Argue line items, quantities, code items, and pricing for your own work
Recommend that the homeowner file a claim
Answer the adjuster's questions about your estimate

You may not

Negotiate the overall claim settlement for the homeowner
Interpret the policy or advise on coverage and claim rights
Take an assignment of the claim or benefits
Take a percentage of the claim as compensation
Advertise that you will handle the claim or deal with the insurance company for them
Hold yourself out as an adjuster or claim specialist

Penalty: Knowingly acting as an unlicensed adjuster is a class B felony, and the commissioner may issue cease and desist orders and assess a civil penalty of up to $25,000 per violation.

Authority

RCW 48.17.010 defines an adjuster as any person who investigates and negotiates settlement relative to insurance claims, or applies the factual circumstances of an insurance claim to the insurance policy provisions, under property and casualty contracts. A public adjuster is an adjuster employed by and representing solely the financial interests of the insured. The exemptions cover attorneys, marine loss adjusters, salaried insurer and MGA employees, and appraisers or umpires under an appraisal clause. There is no contractor or roofer exemption. RCW 48.17.060(2)(a) bars any person from acting as or holding out as an adjuster without a license. RCW 48.17.063 makes a knowing violation of RCW 48.17.060 a class B felony under Chapter 9A.20 RCW and authorizes cease and desist orders, license suspension or revocation, and a civil penalty of not more than $25,000 per violation. RCW 48.17.390 and RCW 48.17.410 establish the separate public adjuster license, limit adjuster authority to investigating and negotiating claim settlement or applying policy provisions, and bar a concurrently licensed adjuster from representing both insurer and insured in the same transaction. Two qualifications. Chapter 18.27 RCW, contractor registration, says nothing about insurance claims, adjusting, or deductibles; its only insurance provision, RCW 18.27.050, concerns the contractor's own liability coverage. And no Washington OIC bulletin or reported decision applies the adjuster definition specifically to roofing contractors, so the reach follows from the statutory definition rather than an express prohibition on contractors.

RCW 48.17.010 — Definitions ("adjuster," "public adjuster," exemptions) · RCW 48.17.060 — License required (no person may act as or hold out as an adjuster unless licensed) · RCW 48.17.063 — Unlicensed activity: class B felony; cease and desist; civil penalty up to $25,000 per violation · RCW 48.17.410 — Authority of adjuster; independent vs. public adjuster · RCW 48.17.390 — Separate licenses for independent, public, or crop adjusters · WAC 284-17-123 — Resident and nonresident adjuster licenses (OIC licensing rule) · Chapter 18.27 RCW — Registration of contractors (documented absence: no insurance-claim, adjusting, or deductible provision)

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