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Appraisal clause in auto insurance: a supplement decision that holds

The appraisal clause in auto insurance lets the insurer or the policyholder send a dispute over the amount of loss to two appraisers and, if needed, an umpire. Washington made the clause mandatory from 2026 and wrote its steps into law. This guide explains how it works, and what a supplement decision in Estimate & Supplement Review needs on file to survive it.

Updated · 14 min read

An appraisal clause in auto insurance is the policy provision that lets either the insurer or the policyholder, when they cannot agree on the amount of a loss, demand that each side appoint an appraiser, with an umpire to settle what the two cannot agree; the amount agreed by any two of the three is binding. It covers the size of the loss, such as the cost to repair or the car's value, not whether the loss is covered. Since 1 January 2026 every Washington auto policy with first-party physical damage cover that is issued or renewed must contain one, in wording set by statute. For a desk appraiser, the practical consequence is that any amount cut from a supplement may one day be re-appraised line by line by someone else, and a decision survives that only if each amount not agreed carries its photo, its rule and its reason.

That is the standard Estimate & Supplement Review is built to: Botminds' software for checking estimates, supplements and repair invoices line by line against the photos, the policy and local prices, with the desk appraiser deciding every line and signing. The example on this page is a fictional sample claim, a rear-ended 2022 Honda Accord in Ohio with fictional shop, carrier and people. The laws quoted are real and current as of October 2026; this is not legal advice.

Washington’s standard auto appraisal clause in four numbers

10days

for each side to choose a competent and disinterested appraiser after a written demand

30days

for the appraisers to complete their appraisals, unless one gives a reason for more

15days

to agree an umpire before either appraiser can ask the commissioner to name one

2of 3

agreements needed for a binding amount: both appraisers, or one with the umpire

From the clause language in Engrossed Senate Bill 5721, Chapter 394, Laws of 2025, required in Washington policies with first-party physical damage coverage issued or renewed on or after 1 January 2026. Each side pays its own appraiser; the umpire's cost is split.Source: Washington ESB 5721, Chapter 394, Laws of 2025 (now RCW 48.18.620)

What is an appraisal clause in insurance?

It is a dispute-resolution term in the policy for disagreements about amount. Washington's statute gives the clearest modern text, which every covered policy must now contain or match with language the insurer certifies is at least as favorable to the insured: "If . . . (the insurance company) . . . and . . . (the policyholder) . . . are unable to agree as to the amount of loss, either party may make a written demand for an appraisal, and within 10 days each party shall select a competent and disinterested appraiser and notify the other party of its selection."

The appraisers then each value the loss, "make separate findings regarding the amount of loss for each element of loss, and exchange their completed appraisals." Where they disagree, an umpire decides between them. "Competent" means subject-matter expertise, training and experience; "disinterested" means no direct financial interest in the outcome. The words "each element of loss" are the ones that matter for supplement review: an appraisal is itemized, so the insurer's side has to defend each disputed line, not a total.

Is an appraisal clause required in auto insurance?

In Washington, yes, for policies with first-party physical damage cover issued or renewed from 1 January 2026; elsewhere it depends on the policy. Washington's law passed the Senate 46 to 2 and the House 96 to 1 and was signed on 20 May 2025. Texas considered the same idea in 2023: the House Insurance Committee's analysis of HB 1437 noted that "Under current law, insurance companies are not required to include an appraisal process in their policies", but the bill stalled in the Senate in May 2023 and did not become law (bill history).

Where a policy has the clause, regulators already assume it. California's total-loss rule lists invoking "the appraisal provision of the insurance policy" among an insurer's options when an insured reports, within 35 days, that a comparable car cannot be bought for the settlement, and Washington's amended rules for total losses require an insurer to tell its appraiser the valuation methods the rule sets, and to disregard any non-compliant valuation when applying an award. Check the policy before assuming either side can demand appraisal.

Who can be an umpire under Washington's clause?

Anyone the two appraisers agree on, provided the person is competent and disinterested. If they cannot agree within 15 days, either appraiser can ask the Insurance Commissioner, who names a registered umpire. Washington's rule for that register, WAC 284-20-310, took effect on 31 January 2026, and sets a high bar.

To be a registered umpire for Washington auto appraisals

RequirementWhat the rule asks for
ExperienceAt least five years as an appraiser of auto claims or a collision repair specialist
Umpire recordAt least five appointments as umpire on an appraisal panel
EducationAn associate degree or equivalent in auto repair, or a professional auto repair certification from the Inter-Industry Conference on Auto Collision Repair, a vehicle manufacturer or the National Institute for Automotive Service Excellence, or an equivalent
Appraisal credentialAn appraisal certification or designation from one of four named appraiser bodies, or an equivalent
Before each panelA signed attestation that the umpire is competent and disinterested as the statute defines them
WAC 284-20-310, adopted by the Insurance Commissioner on 31 December 2025 and effective 31 January 2026. A registered umpire is named only when the parties' appraisers cannot agree on one.Source: Washington State Register WSR 26-02-038 (WAC 284-20-310)

What happens when you disagree with the insurance estimate?

There is a ladder, and appraisal is near the top of it. Most disputes about a repair estimate or supplement end lower down, once the insurer has given its reasons and the shop or owner has answered with evidence. The steps below apply to a first-party auto claim in the states named; a third-party claimant has no contract with the other driver's insurer and normally no appraisal right under it.

The ladder for a disputed repair estimate, from a written reason to the courts

  1. 1

    Ask for every reason, in writing

    Washington requires all of the reasons for paying less than the shop’s estimate, with the cited policy provision explained; California requires each adjustment and its cost to be identified.

  2. 2

    Put a higher estimate in front of the insurer

    In California and Ohio the insurer must then pay the difference or name a shop that will do the repair for its figure; California also allows a reasonable adjustment of the shop’s estimate, itemized.

  3. 3

    Ask for an in-person inspection

    In Washington, after a disputed virtual inspection, the insurer must inspect in person within five business days or another agreed time.

  4. 4

    Invoke the appraisal clause

    For disputes about the amount of loss, not coverage. In Washington, every policy with first-party physical damage cover issued or renewed from 1 January 2026 must have one.

  5. 5

    Complain to the regulator, or go to court

    Appraisal settles an amount; it does not decide whether a practice was unfair or whether a loss is covered.

Steps drawn from Washington's amended WAC 284-30-390 and ESB 5721, California's 10 CCR 2695.8(f) and Ohio Adm. Code 3901-1-54(H)(1). The order is typical, not required; a claimant can skip steps, and a policy's own terms govern appraisal outside Washington.Source: Washington State Register WSR 26-17-089; Washington ESB 5721, Chapter 394, Laws of 2025 (now RCW 48.18.620); 10 CCR 2695.8 (California; Cornell LII copy)

California's rule sets out the insurer's three options once the claimant produces a higher written estimate: pay the difference; name at least one shop that will do the repair for the insurer's amount; or reasonably adjust the shop's estimate and give a copy to the claimant and the shop. An adjusted estimate "shall identify the specific adjustment made to each item and the cost associated with each adjustment made to the claimant's shop's estimate." New York adds a formal notice: if negotiation does not reach an agreed price, the insurer must send the prescribed Notice of Rights letter (11 NYCRR 216.7(b)(14)).

What does the insurer have to tell me if it pays less than my shop's estimate?

Every reason, in writing, tied to the policy. Washington's amended rule is now the most demanding. If an insurer pays less than the estimate from the claimant's chosen shop, it must "promptly and fully disclose all of the reasons it paid less than the claimant's estimate, including a reasonable explanation of the cited policy provision to reject the claimant's repair estimate or invoice, and must thoroughly document the circumstances in its claim file." It must also document in writing any repair costs in its estimate that the policy does not cover, citing the policy language, and on request explain how labor and material costs and repair processes were determined.

The national template points the same way. The NAIC's model unfair claims law treats as unfair "Failing in the case of claims denials or offers of compromise settlement to promptly provide a reasonable and accurate explanation of the basis for such actions" when done flagrantly or as a general business practice; state versions differ. Washington has gone further: its amended rule deletes the words "with such frequency as to indicate a general business practice" from its purpose section, so a violation no longer has to be shown to be a general business practice.

Four appraisal practices Washington treats as unfair

Washington's claims rule, as amended in 2026, lists four ways an insurer can mishandle appraisal, each an unfair claims settlement practice in its own right (WAC 284-30-330, as amended by WSR 26-17-089):

The first of these turns the appraisal award into a measure of the original decision. If the award comes in well above the insurer's offer, the question becomes whether the offer was substantially less than the amount owed. That is a question about the supplement review that produced the offer, which is why the file behind each cut line matters more than the total.

The defensible file: the tests every cut line must pass

A cut line survives appraisal, a complaint or an examiner when someone who was not there can see why it was cut. The NAIC's model regulation states the general standard, that each claim file must contain "Detailed documentation" sufficient "to permit reconstruction of the insurer’s activities relative to each claim", and Washington adds that the insurer is responsible for the documentation that supports how its repair estimate meets the policy language. Translated to a supplement line:

Six tests for every amount not agreed on a supplement

  1. The evidence is on the line

    A dated photo, measurement or log entry that shows the part or the work, kept unaltered. Washington lets insureds request photographs, estimates and reports from their claim file.

  2. The rule or price source is named

    The labor rate survey, guideline time or price list, with its date. In Washington the data source must be disclosed on request.

  3. The policy reason is stated

    Where coverage is the reason, the provision is cited. Washington requires the policy language for costs not covered.

  4. The dollars are itemized

    Each adjustment and its cost, line by line, so an appraiser can find each element of loss.

  5. What would change it is said

    A missing photo or measurement is asked for, not held against the line. In Washington, more documentation must be sought before damage a photo does not show is rejected.

  6. Who decided, and when, is recorded

    The appraiser’s decision and any co-signature, with dates, so the insurer’s activities can be reconstructed.

Our tests, each drawn from Washington's amended WAC 284-30-330, -340, -380 and -390, ESB 5721 and NAIC Model Regulation 902. Not legal advice.

One cut line, two ways

The sample supplement shows the difference. Kestrel Auto Body's supplement S1 added a front bumper cover, $892.00, to a car hit from behind. The line was not agreed. What matters for appraisal is how.

The same disputed line, as a phone call and as a defensible decision

Cut by phoneCut on the record, as in the sample note
The reason

Cut by phone: "That wasn’t in the original damage."

Cut on the record, as in the sample note: Rear impact; photos P4 and P5 of 26 September show the front bumper cover intact, gaps even, paint unbroken; none of the six teardown photos shows the front.

The evidence

Cut by phone: In the appraiser’s memory, or a photo nobody attached.

Cut on the record, as in the sample note: P4 and P5 attached to the note, originals with date and author.

The amount

Cut by phone: A lower total.

Cut on the record, as in the sample note: S1-4 billed $892.00, agreed $0.00; S1-5 grille $38.40 goes with it.

What would change it

Cut by phone: Another call.

Cut on the record, as in the sample note: “If the front cover is damaged, please send photos of it and we will look again.”

Who decided

Cut by phone: Unclear.

Cut on the record, as in the sample note: Desk appraiser signed 09:26; supervisor co-signed 09:31; sent 12 October through the repair portal.

In an appraisal

Cut by phone: The insurer’s appraiser starts from nothing.

Cut on the record, as in the sample note: The element of loss is already isolated, evidenced and explained.

Fictional sample claim AP-26-118402. The right-hand column is taken from the sample note to the shop; the left is a composite of what the rules are written to prevent.

The disputed line, shown on the earlier photo of the same part

The supplement check screen for line S1-4, replace and refinish front bumper cover, $892.00, contradicted by photo. A then-and-now slider shows field photo P4 of Sep 26 2026, front left three-quarter, with the headlamp and front bumper cover boxed as intact, beside teardown photo T1 of Oct 8 2026 showing the rear bumper cover removed. A panel reads: contradicted by photo; the loss was a rear impact; P4 and P5, taken by Nora Quist on Sep 26, show the front bumper cover intact, gaps even, paint unbroken, no scuffs; none of the six teardown photos shows the front of the car. Evidence thumbnails P4 and T1, then agreed $0.00, disputed $892.00, and the appraiser's decision buttons Dispute and Pay as billed.
Fictional sample claim. The evidence for the disputed element of loss is assembled when the decision is made, not when an appraisal is demanded.

Under the solution, the note writer drafts that note from the findings and the desk appraiser signs it: every amount not agreed is listed with its photo in the margin and its reason, and the note says what the shop can send to change the answer. A line with no photo is held, never cut, so the file never contains a rejection that rests on an absence of evidence.

Every amount not agreed, with its photo and its reason

A drafted note to Dale Kovacs, estimator, Kestrel Auto Body, Grove City, Ohio, headed Supplement S1, $1,409.00 agreed today. It lists the labor rate adjustment on four lines with the rate survey in the margin, then S1-4 replace and refinish front bumper cover, billed $892.00, agreed $0.00, not agreed $892.00, with photo P4 of Sep 26 2026 in the margin and the reason, and S1-5 front bumper lower grille, not agreed $38.40, with photo P5, and S1-7 rear body panel, more hours, billed $160.00, agreed $58.00. A sign-off panel shows the note writer's draft, the appraiser's signature and the supervisor's co-signature.
Fictional sample note. Each disputed element of loss is already separated, evidenced and priced, which is the form an appraisal will need.

Can I dispute a supplement denial?

Yes. The first step is to ask for the reason for each line in writing and answer it with evidence: a photo of the part, a measurement, the repair procedure. In the sample file, the front bumper line came with an explicit route back: send photos of the front cover. Where the dispute is about amount, a first-party claimant can then invoke the appraisal clause if the policy has one, and in Washington every new or renewed policy with first-party physical damage cover now does.

Disputes about labor rates, hours and blend are the commonest amounts at issue on supplements, and they are only as strong as their sources; how the prevailing labor rate is set and the thresholds behind blend and overlap lines cover the two most frequent. What Estimate & Supplement Review does not do is take part in an appraisal: it does not appoint appraisers, argue values or predict awards. It makes sure that what the insurer's appraiser receives is a set of decisions that were already evidenced when they were made.

Questions people ask

How long does an auto insurance appraisal take?

Under Washington's standard clause, each side has 10 days to choose an appraiser after a written demand, and the appraisers have 30 calendar days from selection to complete their appraisals, unless one gives a reason for more before day 25. If they disagree and cannot agree an umpire within 15 days, either can ask the commissioner to name one. Policies elsewhere set their own timetables.

Who pays for appraisal in auto insurance?

Under Washington's clause, each party pays its own appraiser and the two share the umpire's cost equally. Other policies vary. Texas's 2023 bill would have made the insurer refund the policyholder's appraiser fees when the award beat its last offer by more than 10 percent, and the policyholder pay the insurer's when the award came in more than 10 percent below it, but the bill did not become law.

Is an appraisal award binding?

The amount agreed by any two of the three, the two appraisers or one appraiser and the umpire, is binding under Washington's clause. Appraisal settles the amount of loss; whether a loss is covered at all is not an appraisal question.

Can the insurer tell its appraiser to lower the number?

Not in Washington, where it is an unfair claims practice to require an appraiser functioning under the appraisal clause to adjust their actual cash value or valuation of loss at any time during the appraisal; the insurer may still apply the policy's conditions to a completed award.

Can the body shop invoke the appraisal clause?

The clause is between the insurer and the policyholder; Washington's text gives the right to "either party" to the policy. A shop can supply the estimate, photos and procedures the owner's appraiser relies on, and in Washington the owner can ask to be copied on all communications between the insurer and the shop about estimates.

Estimate & Supplement Review.
See it on your own files.

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