Pet insurance in Vermont

Enacted in 2024, in force since 1 July 2025

The law is 8 V.S.A. §§7151–7159, Chapter 149, the “Pet Insurance Act.” Section 28 of Act 110 (H.659), an act on banking, insurance and securities, created it. The Governor signed the act on 20 May 2024; the date appears in the act itself and on the bill page. Section 28 took effect on 1 July 2025. The statute’s history notes cite the act as “2023, No. 110 (Adj. Sess.)”: that is the second half of the 2023–2024 session, not the year 2023.

Under §7152, the law applies to policies issued to Vermont residents and sold, solicited, negotiated or offered in the state, and to policies or certificates delivered or issued for delivery there. Other insurance law still applies, but the chapter’s specific provisions override general ones. Pet insurance is property insurance (§7153(c)(5)). Violations carry the penalties of §3661 (§7159); the orders below describe these as up to $1,000 per violation and $10,000 per willful violation.

The key caveat is §7153(b): the law does not “in any way prohibit or limit the types of exclusions.” It sets definitions and minimum guarantees but does not require coverage of chronic, hereditary or congenital conditions.

Waiting periods and examinations

§7155(b) and related rules:

If a policy has a waiting period, the contract must let it be waived after a medical examination. The insurer may require the exam to be done by a licensed veterinarian after purchase and may specify what it covers and what documentation is needed. Those requirements must not unreasonably restrict the waiver. The policyholder pays for the exam unless the policy says otherwise. Waiting periods and waiver requirements must be disclosed before purchase.

“No waiting period” does not always mean “covered tomorrow.” The law lets such a policy start up to 15 days after purchase. For the owner, that is a waiting period under another name.

Pre-existing conditions: 180 days only

Under §7153(c)(6)(A), a condition is pre-existing if, within 180 days before the policy’s effective date or during a waiting period:

1. a veterinarian gave medical advice about it;
2. the pet received treatment for it; or
3. verifiable sources show the pet had signs or symptoms directly related to the condition claimed.

Of the 17 laws we have read, Vermont’s is the only one that limits this look-back. An insurer that uses the term must use the statutory definition and include it in the policy (§7153(a)).

The insurer must prove that the exclusion applies (§7155(a)). A condition covered by the policy cannot become pre-existing on renewal (§7153(c)(6)(B), §7155(f)). Renewal means a new policy at the end of the term from the same or an affiliated insurer with substantially similar types and limits of coverage (§7153(c)(7)). Switching to another company does not carry coverage history over.

The loophole is the same §7153(b): the types of exclusions are not limited. So the samples below put clauses with no time limit next to the 180-day definition: signs “detectable by a routine physical exam,” ligament and knee problems “at any time” before coverage, a prior cancer of the same type “at any time.” In our reading, these work around the 180-day rule. We found no regulator or court ruling on the point.

The regulator, the Department of Financial Regulation (DFR), publishes a Pet Insurance Certification Checklist, its requirements for pet-insurance form filings. The document is undated; its PDF metadata dates it to 2019. On 11 November 2026 it was still linked under Pet Insurance on the DFR property and casualty page. The checklist predates the law. It does not allow a definition to include conditions a veterinarian did not discover, diagnose or treat, and it limits signs masked by medication to 6 months. The 2024 law expressly allows the third prong: symptoms shown by verifiable sources. How DFR now reconciles the checklist with the law has not been established.

Coverage changes, missed payments and price

Three provisions of §7155 that are not in the NAIC model:

• (g) a policyholder may change coverage amounts without the policy being cancelled and reissued;
• (h) coverage for new or existing claims is not suspended for nonpayment; the policy stays in effect until renewal, cancellation or nonrenewal;
• (i) unpaid premium may not be deducted from a claim payment.

The DFR checklist puts it more bluntly: an insurer may not cancel and reissue a policy when the customer increases or decreases coverage; that violates 8 V.S.A. §3879. The law does not say whether the added layer of coverage can carry a new waiting period or a new pre-existing review.

The law does not prohibit raising premiums because of claims. §7154(a)(4) only requires disclosure of whether the insurer reduces coverage or increases premiums based on claim history, the pet’s age or a move. Fetch’s and Pumpkin’s Vermont notices say plainly that premiums may rise because of claims; Fetch’s adds that coverage may be reduced.

Disclosures and 30 days to return the policy

§7154 requires the insurer to disclose:

• whether the policy excludes pre-existing, hereditary, congenital or chronic conditions;
• waiting periods, deductibles, coinsurance and annual or lifetime limits;
• whether claim history, age or a move affect price or coverage;
• the formula used to calculate claim payments;
• whether the underwriting company differs from the brand.

The summary must be a separate document titled Insurer Disclosure of Important Policy Provisions, linked from the main page of the website and delivered with a new policy in at least 12-point type. If an exam is required for coverage, its requirements must be disclosed before purchase, with a warning that exam records may lead to a pre-existing exclusion. When the policy is issued, the insurer must include DFR’s mailing address, toll-free number and website in 12-point bold type.

The right to return the policy (§7154(b)):

1. If no claim has been filed, you may return the policy within 30 days after receiving it, without giving a reason.
2. The full premium must be refunded to whoever paid it within 30 days after the insurer receives the returned policy. The policy is void as if never issued.

The clock runs from receipt of the policy, not from its effective date. Many samples below count from the effective date instead.

A wellness program sold separately must be disclosed as not insurance; buying one cannot be a condition of buying a policy, and its price and terms must be separate (§7155(e), §7156). “Wellness” benefits inside the policy are insurance (§7155(d), §7156(b)(7)).

Cancellation, nonrenewal and the renewal price

Chapter 149 has no cancellation rules of its own. The DFR checklist applies the general 8 V.S.A. §§3879–3883 to pet insurance: “Applicable to all Pet Insurance policies.”

Without that confirmation 45 days ahead, §3882(b) requires renewal coverage for 45 days after the insurer confirms, at the expiring premium or at rates lawfully in effect on the expiration date. The statute does not say which of the two the insurer chooses. Keep renewal letters and note when they arrived.

Claims: the deadlines in Regulation I-79-2

Regulation I-79-2 (revised effective 1 July 2018) applies to all policies except workers’ compensation, title and surety:

Every payment must explain how it was calculated: deductible, coinsurance, deductions. Violations count as an unfair practice when they occur often enough to indicate a business practice (§4724(9)). We did not check the time limit for suing an insurer.

The DFR checklist adds requirements for policy forms:

• mandatory binding arbitration or appraisal that one side can demand unilaterally is not permitted;
• veterinary examination fees and charges such as medical waste fees may not be excluded;
• medical expenses must be described as “reasonable” or “necessary,” not “usual” or “customary”;
• a policy obtained by fraud may be voided; fraud in presenting a claim allows denial of the claim and cancellation, but not voiding;
• a pregnancy exclusion must be disclosed before purchase.

The checklist sets out the department’s filing requirements; it is not a statute or regulation. We do not know whether DFR approved each sample below.

Rates are filed 30 days before use

From 1 July 2025, Act 23 (H.137) amended §4688(a): rates, supplementary rate information and supporting information must be filed no later than 30 days before the effective date, instead of within 15 days after it. The Governor signed the act on 19 May 2025.

Regulation I-2010-03 (effective 2011) still says “15 days after” in §8(B). Bulletin 236, signed on 29 August 2025, explains that the statute supersedes the rule where they conflict. The 30 days start only when DFR receives a complete filing, with the fee and all supporting information. If a filing is incomplete, DFR sends an Objection Letter, and the rate may not be used until 30 days after the missing information arrives.

What this means for prices:

• a market is presumed competitive unless the Commissioner finds otherwise (§4684). If average rates in a market rise 15% to 25% over 12 months, the Commissioner holds hearings, unless satisfied that the market is still competitive. An increase of 25% or more can lead to a finding that the market is not competitive. These are market averages, not a cap on your premium;
• in a competitive market, a rate is by law not excessive (§4685(b)(1)). The Commissioner may disapprove it only as inadequate or unfairly discriminatory (§4689(b)(1)). “Too expensive” is not, on its own, a ground;
• the DFR checklist bars annual trend factors in pet rate manuals, meaning a built-in automatic yearly price increase.

What an owner can do under §4704: ask the insurer in writing how the premium was developed and applied (it must answer within a reasonable time, for a reasonable charge if any), and ask for a review of how the filing was applied to you. If 25 people are aggrieved, they may appeal in writing to the Commissioner, who may hold a hearing.

Policy forms need approval in advance (§3541): filing at least 30 days before delivery; a form is deemed approved if no decision is made by then; the Commissioner may extend the period by 30 days. The Commissioner disapproves forms with inconsistent, ambiguous or misleading clauses (§3542). The regulation narrows the exemption for “specially rated” inland marine risks to unique, “one of a kind” risks. In our reading, a mass-market pet product is not one.

Getting the filings

Rates, supplementary information and nonproprietary supporting information are open to inspection as soon as filed, and any person may obtain copies for a reasonable charge (§4688(e)). Under Regulation I-2010-03, a filing is a public record from the moment DFR receives it unless the insurer obtained trade-secret status.

DFR names two routes: public access to non-confidential filings through SERFF, or review in its office by appointment, 802-828-2908. Public Records Act requests go to DFR’s records officer: [email protected], 802-272-5965.

We did not open or request Vermont pet filings.

DFR orders against pet insurers

These orders concern licensing, not whether claim decisions were right; they do not find wrongful denials. The IAIC order names no brand. IAIC is the insurer in the Pets Best, ASPCA, Figo and Pumpkin samples below, but the order does not tie those claims to any brand.

The market in NAIC data

The NAIC 2025 market share report (August 2026, line 09.2 Pet Insurance) shows Vermont pet insurance direct premiums written of $14,545 thousand and earned premiums of $14,480 thousand. That is 0.27% of the total for US states and territories. Vermont’s loss ratio was 65.24%, against 68.10% for states and territories overall.

The largest groups: Trupanion, 32.93%; JAB Holding, 25.70%; Nationwide, 15.07%; Munich Re, 7.99%; Chubb, 7.84%; Metropolitan, 4.85%; AXIS Capital, 4.28%. These are one year’s figures by group, not a policy price or a particular brand’s share.

Where brand samples diverge from the law

On 11 November 2026, brands published the following Vermont documents. A sample does not prove the policy is sold today or that an issued contract matches it.

Below is where, in our reading, the samples diverge from the law or DFR’s requirements. We found no regulator ruling on these forms.

Pets Best: cancel and reissue. Under 4.A.2, raising the annual limit or adding a supplemental benefit requires cancelling the policy and issuing a new one, with new waiting periods and a new pre-existing review. The Vermont endorsements do not touch section 4. That conflicts with §7155(g) and the express prohibition in the DFR checklist. Under 3.B, after nonpayment the policy is cancelled retroactively, “back to the date to which your premiums were paid.” The law says nonpayment does not suspend coverage before cancellation (§7155(h)).

Pets Best: waiving the wait. Endorsement MLAE-VT waives waiting periods when a veterinarian certifies the pet’s health after an exam before coverage is purchased, and adds “at our discretion.” The law requires the contract to allow a waiver after an exam and lets the insurer require that exam after purchase.

Healthy Paws: exam fees, hip dysplasia and “detectable by a routine exam.” The Vermont amendment LD-50796 itself excludes “Veterinary examination fees,” although the DFR checklist says Vermont does not approve that exclusion. Of the base limitations, the amendment replaces only II.5.a; II.5.b stays: for pets enrolled at 6 or older, hip dysplasia is not covered. The Vermont disclosure lists the 30-day hip dysplasia wait without mentioning this. Base II.4.h excludes abnormalities with clinical symptoms apparent before the policy started: “This includes conditions that are detectable by a routine physical exam by your veterinarian.” II.4.e excludes the other leg if a cruciate problem existed before coverage. The amendment leaves both in place, with no 180-day limit. The deductible or coinsurance can be lowered only if no claim has been filed for that pet (III.7). Suits must be brought within one year of the loss unless state law requires a longer period (III.12). Nonpayment cancellation notices go by email; whether that satisfies §§3880 and 3883 has not been established.

ASPCA: the endorsement hits the wrong clause. Endorsement PET-AE-20000-VT-0723 replaces exclusion “p” with a non-veterinary-services exclusion that omits medical waste. But in form PET-P-20000-VT-1024, item p is non-medical supplies; the non-veterinary-services exclusion that names “medical waste” is item q. Read literally, q still applies. The form also treats a condition as occurring when signs “would have been detectable by a routine physical veterinary exam,” and excludes ligament and knee conditions if one ever occurred before coverage. The 12-page sample has no notice of the 30-day return right counted from receipt.

Figo: voiding for claim fraud. The form makes the policy void for fraud “at any time,” including in a claim. The DFR checklist allows the claim to be denied and the policy cancelled in that case, but not voided. Pets Best and ASPCA have similar clauses. Pets Best 5.A.8 lets it refuse the claim and void the policy for “false, misleading, and/or dishonest information”; the Vermont endorsements leave it in place. ASPCA’s insuring agreement lets it “cancel, invalidate or rescind coverage” for intentional misrepresentation or concealment of a material fact; the Vermont endorsement replaces When We Cancel, not this paragraph. Figo excludes exam fees unless optional coverage is bought. In the owner’s favor, the pre-existing exclusion expires after 365 days of continuous coverage. But a prior cancer of the same type and any ligament or knee condition “at any time” before coverage are excluded by separate clauses.

Embrace V6: general text without Vermont changes. The V6 page has no Vermont-specific text. Its free-look notice gives 15 days from receipt, not 30; a separate clause refunds the premium if you cancel within 30 days of the first term’s effective date and have made no claim. Its pre-existing definition has no 180-day limit. Four canine orthopedic conditions (cruciate ligament disease, IVDD, patellar luxation and hip dysplasia) that show signs in the first 180 days are excluded for the life of the policy, although the law allows waiting periods of no more than 30 days. A text search found no way to waive the 14-day waiting period after an exam, which the law requires. Increasing coverage restarts the waiting period and the pre-existing review. Cancellation notice periods are 10 and 30 days instead of 15 and 45. We did not check whether Embrace issues separate Vermont endorsements.

Fetch: wrong regulator contact details. Its Vermont notice (updated 13 September 2026) calls the regulator the “Department of Financial Services,” gives ZIP code 06620 instead of 05620, and lists a misspelled email address as the website. The correct details are on the DFR website: 89 Main Street, Montpelier, VT 05620-3101; consumer line 802-828-3302; toll-free 833-337-4685. Fetch accepts claims no later than 90 days after treatment.

We did not open Trupanion samples: the site previously returned HTTP 403. Nationwide, Spot, MetLife, Lemonade and other brands were not checked.