Arizona · Insurance Adjuster Sample Interactive Mind Map
Arizona Adjuster Regulations
A visual breakdown of the Arizona rules an adjuster is tested on — including the single license that covers both sides of the claim, the staff exclusion that turns on how you are paid, the closed list of sixteen imported sections, the clocks that mix working and plain days, and the two acts that change the article on 12 September 2026.
Arizona's adjuster statute is three sections long — § 20-321, § 20-321.01 and § 20-321.02 — and almost every distinctive feature of Arizona adjuster regulation follows from that brevity. There is one adjuster license, and it covers work “on behalf of either the insurer or the insured.” Arizona has no public adjuster credential. The staff exclusion at § 20-321(1)(b)(ii) does not turn on employment status the way most states' do — it turns on whether compensation is contingent on the outcome of a claim determination, so a W-2 employee on a claims-outcome bonus is not exempt. And a pure workers' compensation adjuster is triple-excluded: outside the definition, outside the claims rule, and outside the bad-faith tort.
Because the article is so short, § 20-321.02 does the heavy lifting by importing a closed list of sixteen producer sections — and what is missing from that list is as operative as what is on it. § 20-294 was never imported, so there is no temporary adjuster license. § 20-300 was never imported, so producer reciprocity does not govern. And although § 20-289(C)(3) appears to condition renewal on continuing education, the chapter it points at defines its own “licensee” as an insurance producer — so the condition is empty as to adjusters. Arizona requires no continuing education at all, and neither the vendor nor the Department publishes a passing score.
On the job the same pattern repeats: the answer depends on which instrument you read. § 20-461 requires a general business practice; A.A.C. R20-6-801 requires nothing of the kind, so a single act violates the rule. § 20-461(D) then forecloses a private action for any violation of the section “or rule related to this section” — the bar reaches the regulation too. The rule's clocks mix working days and plain days, and the headline 30-day investigation deadline is the one in plain days. It states no record retention period. First-party bad faith is a live and demanding tort where fair debatability is necessary but not sufficient, yet an adjuster cannot be sued personally, because bad faith requires a contractual nexus the adjuster does not have. Arizona is a pure comparative fault state with no recovery bar at any percentage. And on 12 September 2026 two acts add a definition that renumbers § 20-321, sweep solicitors into the license, and impose the first statutory conduct rules ever placed on Arizona adjusters.
Arizona issues ONE adjuster license, and it covers both sides of the claim.
The article is Title 20, Chapter 2, Article 3.2 and it has three sections: § 20-321 (definitions), § 20-321.01 (licensing) and § 20-321.02 (application of other laws). § 20-321(1)(a) defines an adjuster as a person who investigates or negotiates settlement of claims “on behalf of either the insurer or the insured.” There is no public adjuster license in Arizona — insured-side work is done under the same credential.
The article is Title 20, Chapter 2, Article 3.2 and it has three sections: § 20-321 (definitions), § 20-321.01 (licensing) and § 20-321.02 (application of other laws). § 20-321(1)(a) defines an adjuster as a person who investigates or negotiates settlement of claims “on behalf of either the insurer or the insured.” There is no public adjuster license in Arizona — insured-side work is done under the same credential.
💼 WORKING FOR THE INSURER
🏠 WORKING FOR THE INSURED
Company, independent and catastrophe work. Same license, same $120 fee, same four-year term.
What most states call a public adjuster. Same license. No separate bond, no filed contract, no statutory fee cap — until 12 September 2026 adds three conduct rules (cluster 5).
§ 20-321(1)(b) — NINE EXCLUSIONS, NOT FIVEThe Department’s own “who must be licensed” page lists five. The statute has nine. The four it omits include the twenty-five-person data-entry exclusion and the single most commercially significant one in the state — workers’ compensation. An agency’s plain-language summary is a lead, not the law.
| § 20-321(1)(b) — the nine | Item | What it turns on |
|---|---|---|
| Attorneys | (i) | Acting in the ordinary relationship of attorney and client |
| Salaried employees | (ii) | ⚠ Only where pay is not contingent on claim outcomes |
| Producers | (iii) | Adjusting losses under policies they sold |
| Political subdivision employees | (iv) | Omitted from the Department’s summary |
| Technical assistance contractors | (v) | Photographers, estimators, engineers, private detectives, handwriting experts |
| Data-entry personnel | (vi) | ⚠ 25 per licensed adjuster or producer — a span of control, not a job title |
| Supervising producers | (vii) | Producers supervising the data-entry personnel above |
| Registered TPAs | (viii) | Accident and health, or life claims |
| Workers’ comp only | (ix) | ⚠ Excluded entirely. No Arizona adjuster license required |
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The staff adjuster test turns on HOW YOU ARE PAID — not on who employs you
Most states frame the staff exemption around employment status: employee in, contractor out. Arizona frames it around compensation. The exclusion at (ii) covers a salaried employee whose compensation is not contingent on the outcome of a claim determination.
⚠ So a W-2 employee on a claims-outcome bonus is NOT exempt, and a genuinely salaried employee is exempt whatever the paperwork calls them. The question Arizona asks is not how you are engaged. It is whether your pay moves with claim outcomes.
⚠ So a W-2 employee on a claims-outcome bonus is NOT exempt, and a genuinely salaried employee is exempt whatever the paperwork calls them. The question Arizona asks is not how you are engaged. It is whether your pay moves with claim outcomes.
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A pure workers’ compensation adjuster is TRIPLE-excluded
Three separate instruments each remove the comp-only adjuster, and they stack:
1. § 20-321(1)(b)(ix) — outside the definition of “adjuster.” No license.
2. R20-6-801(A) — the claims rule excepts “policies of Worker’s Compensation and title insurance.” No claims rule.
3. § 23-930 — the Industrial Commission has exclusive jurisdiction over comp bad faith. No tort.
Civil penalty up to $1,000 per violation, plus a claimant benefit penalty of 25% of the benefit ordered or $500, whichever is more.
1. § 20-321(1)(b)(ix) — outside the definition of “adjuster.” No license.
2. R20-6-801(A) — the claims rule excepts “policies of Worker’s Compensation and title insurance.” No claims rule.
3. § 23-930 — the Industrial Commission has exclusive jurisdiction over comp bad faith. No tort.
Civil penalty up to $1,000 per violation, plus a claimant benefit penalty of 25% of the benefit ordered or $500, whichever is more.
✅ WHAT ARIZONA DOES HAVE
§ 20-321.01(D) — a blanket catastrophe exemption: licensed in your domicile and sent by an insurer, and you may work an Arizona catastrophe with no Arizona license
§ 20-321.01(C)(3) — the designation waiver, which removes the exam and the residency rule
Portable electronics — a separate license category with a 25-person automated-adjudication span of control
Business entity adjusters — licensed, at the same $120
❌ WHAT ARIZONA DOES NOT HAVE
No emergency or catastrophe LICENSE — the exemption does the work instead, so there is nothing to apply for and no 90-day clock
No temporary license — § 20-294 is not among the sixteen sections § 20-321.02 imports
No public adjuster license — the one license covers insured-side work
No separate workers’ compensation adjuster license
INDIVIDUAL LICENSING IS STILL REQUIREDA business entity adjuster license does not cover the people working under it. Each individual adjusting Arizona claims needs their own license unless one of the nine exclusions applies. And § 41-1030(B) bars the Department from adding a condition the law does not authorize — enforceable by the applicant in a private civil action with fee-shifting under (D).
Three sections, and a scope clause that decides everything else.
Because Article 3.2 is so short, § 20-321.02 does the heavy lifting: it lists sixteen producer sections that apply to adjusters. It is a closed list. Read it in both directions — two of Arizona’s clearest rules are established by noticing an absence.
Because Article 3.2 is so short, § 20-321.02 does the heavy lifting: it lists sixteen producer sections that apply to adjusters. It is a closed list. Read it in both directions — two of Arizona’s clearest rules are established by noticing an absence.
✅ ON THE LIST — SIXTEEN IMPORTED SECTIONS
§ 20-284 — examinations, the four-attempt cap and the one-year score life
§ 20-285 — application and fingerprints
§ 20-287 — nonresident licensing
§ 20-289 — term, renewal, lapse and surrender
§ 20-292 — injunctive relief
§ 20-295 — denial, suspension, revocation, civil penalty
§ 20-296 — effect of suspension or revocation
§ 20-301 — report of actions
❌ CONSPICUOUSLY MISSING
§ 20-294 — TEMPORARY LICENSING. Not imported. So Arizona has no temporary adjuster license, and the negative is proved by enumeration, not by failing to find one
§ 20-300 — RECIPROCITY. Not imported. The producer reciprocity section does not govern adjusters
Nothing imposing continuing education directly — and the one section that appears to (§ 20-289(C)(3)) is hollow (below)
No conduct rules at all — until 12 September 2026 (cluster 5)
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NO CONTINUING EDUCATION — and the reason is a definition two chapters away
The Department states it flatly: “Continuing education not required.” But one provision appears to say the opposite, and it is worth proving from the statute.
§ 20-321.02 imports § 20-289, and § 20-289(C)(3) conditions renewal on evidence of compliance with “the continuing education requirements prescribed in chapter 18 of this title.”
⚠ Then read chapter 18’s own definition. § 20-2901(9) defines its “licensee” as “an individual insurance producer licensed for major line insurance as defined in section 20-281.” And § 20-281(5) defines an insurance producer as a person required to be licensed under the producer article to sell, solicit or negotiate insurance.
An adjuster is licensed under Article 3.2 and sells nothing. So chapter 18 does not reach adjusters, and § 20-289(C)(3)’s condition is empty as to them.
§ 20-321.02 imports § 20-289, and § 20-289(C)(3) conditions renewal on evidence of compliance with “the continuing education requirements prescribed in chapter 18 of this title.”
⚠ Then read chapter 18’s own definition. § 20-2901(9) defines its “licensee” as “an individual insurance producer licensed for major line insurance as defined in section 20-281.” And § 20-281(5) defines an insurance producer as a person required to be licensed under the producer article to sell, solicit or negotiate insurance.
An adjuster is licensed under Article 3.2 and sells nothing. So chapter 18 does not reach adjusters, and § 20-289(C)(3)’s condition is empty as to them.
THE NEGATIVE HOLDS AT THE RULE LEVEL TOOArizona’s licensing rules are A.A.C. Title 20, Chapter 6, Article 7, and eight of its nine sections are repealed or expired. The only live rule is R20-6-708, which binds the Department’s processing clock — 60 / 60 / 120 days — and imposes nothing on the licensee. No article anywhere in Chapter 6 addresses continuing education, and § 41-1030(B) means the Department could not impose one by practice.
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The designation waiver removes the exam AND the residency requirement
§ 20-321.01(C)(3) is normally taught as an exam waiver. It is more than that. An applicant holding an approved professional claims designation satisfies the qualification without the Arizona examination and without the residency requirement.
The approved program must itself require, cumulatively: at least 40 hours of pre-examination coursework, a proctored examination, and at least 24 hours of continuing education biennially for renewal.
⚠ So the one Arizona adjuster with a recurring education obligation is the one who skipped the exam — and the obligation is the certifying association’s, not Arizona’s. Lose the designation and the basis for the license is in question.
The approved program must itself require, cumulatively: at least 40 hours of pre-examination coursework, a proctored examination, and at least 24 hours of continuing education biennially for renewal.
⚠ So the one Arizona adjuster with a recurring education obligation is the one who skipped the exam — and the obligation is the certifying association’s, not Arizona’s. Lose the designation and the basis for the license is in question.
| The examination — what is published and what is not | Figure | Note |
|---|---|---|
| Vendor | PSI | ⚠ The vendor changed. Every figure sourced from the previous vendor is provenance-broken |
| Questions | 150 | AZ Property & Casualty Adjuster |
| Time limit | 2.5 hrs | Confirmed on the current vendor bulletin |
| Passing score | — | ⚠ Not published by the vendor or by the Department. There is no number to learn |
| Exam fee | — | ⚠ Not published. Quoted at scheduling. § 20-167(D) lets it exceed the statutory band |
| Attempts | 4 | Per 12 months, then a one-year wait — § 20-284, imported |
| Score shelf life | 1 yr | Apply within the year or retake |
| Largest content area | 20% | P&C Insurance Basics. ⚠ The outline was reweighted — Adjustment Process is now 11% |
| Fees and term | Figure | Note |
|---|---|---|
| Application / renewal / entity | $120 | Per class of license |
| Late renewal | $100 | On top of the renewal fee |
| Statutory fee band | $60–$180 | ⚠ § 20-167(A) sets a range, quadrennially — the director picks the number, so it can move without a bill |
| License term | 4 years | Unusual — most states run two |
| First term | 3–4 yrs | ⚠ Not less than three. Every secondary summary says four; the statute says the expiry must land on a birth month inside a three-to-four-year window |
| Expiration | — | Last day of the licensee’s birth month |
| Early renewal | 90 days | Before expiration |
| Late renewal window | 1 year | Then a new application |
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Surrender is worse than lapse — know which door you are walking through
A license that simply lapses can be renewed for a full year afterwards with the fee plus $100, and no requalification.
A license that is voluntarily surrendered cannot. § 20-289(F) provides that a person who surrenders “may obtain the same authority or license only if the person complies with the requirements that apply to a person who has not previously held the authority or license.” That means requalification from the beginning, including the examination — a one-year practical bar.
A license that is voluntarily surrendered cannot. § 20-289(F) provides that a person who surrenders “may obtain the same authority or license only if the person complies with the requirements that apply to a person who has not previously held the authority or license.” That means requalification from the beginning, including the examination — a one-year practical bar.
The same question has opposite answers depending on which instrument you read.
Arizona regulates claim handling through a statute and a rule sitting on top of one another, and they set different thresholds for a violation. § 20-461 opens with a frequency chapeau. A.A.C. R20-6-801 has none.
Arizona regulates claim handling through a statute and a rule sitting on top of one another, and they set different thresholds for a violation. § 20-461 opens with a frequency chapeau. A.A.C. R20-6-801 has none.
📜 A.R.S. § 20-461 — THE STATUTE
⚖ A.A.C. R20-6-801 — THE RULE
“A person shall not commit or perform with such a frequency to indicate as a general business practice any of the following…” — then nineteen practices. A pattern is required. Four entries are Arizona’s own, including (16) nonmechanical sheet glass and (19) denying liability under a motor vehicle policy in effect at the time.
No chapeau of any kind. Flat imperatives: “Every insurer shall complete investigation…”, “No insurer shall…” The words “general business practice” and “such frequency” do not appear anywhere in it. A single act violates the rule.
NAME THE INSTRUMENT BEFORE YOU ANSWER“Does Arizona require a general business practice?” is not a question with one answer. Statute: yes. Rule: no. And the rule is the one an adjuster actually works under day to day.
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The rule is a FLOOR, not a ceiling — and it does not reach comp
R20-6-801(A) applies to all persons and all policies “except policies of Worker’s Compensation and title insurance,” and then adds: “This rule is not exclusive, and other acts not herein specified, may also be deemed to be a violation of A.R.S. § 20-461.”
⚠ So complying with the enumerated standards is not a safe harbor from the statute — conduct the rule never names can still be an unfair practice.
⚠ So complying with the enumerated standards is not a safe harbor from the statute — conduct the rule never names can still be an unfair practice.
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NO PRIVATE RIGHT OF ACTION — and the bar reaches the RULE, not just the statute
§ 20-461(D), two sentences, and the second is the one to read carefully:
“Nothing contained in this section is intended to provide any private right or cause of action…”
“It is, however, the specific intent of this section to provide solely an administrative remedy to the director for any violation of this section or rule related to this section.”
⚠ Most states bar a private action on the statute and leave the regulation unaddressed. Arizona’s bar expressly reaches the rule — and R20-6-801 names § 20-461 in its own applicability subsection. So the regulation carries no private enforcement either.
What survives is the common-law tort (cluster 4), because Arizona bad faith is not a § 20-461 action at all. Net: the rule is not a cause of action, is usable as standard-of-care evidence, and is not a jury instruction.
“Nothing contained in this section is intended to provide any private right or cause of action…”
“It is, however, the specific intent of this section to provide solely an administrative remedy to the director for any violation of this section or rule related to this section.”
⚠ Most states bar a private action on the statute and leave the regulation unaddressed. Arizona’s bar expressly reaches the rule — and R20-6-801 names § 20-461 in its own applicability subsection. So the regulation carries no private enforcement either.
What survives is the common-law tort (cluster 4), because Arizona bad faith is not a § 20-461 action at all. Net: the rule is not a cause of action, is usable as standard-of-care evidence, and is not a jury instruction.
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The one rule that looked like it bound the adjuster personally does NOT — since January 2024
R20-6-801(D.2) is the only provision in the whole chapter whose subject is not the insurer: “No agent shall conceal from first party claimants benefits, coverages or other provisions…”
Read with the old definition — “any…entity authorized to represent an insurer with respect to a claim” — it captures the adjuster. The 2024 amendment added a second sentence:
“‘Agent’ has the same meaning as ‘Insurance producer’ as defined at A.R.S. § 20-281(5).”
⚠ So D.2 reaches PRODUCERS, not adjusters — and there is now no provision anywhere in A.A.C. Title 20 Ch. 6 imposing a claim-handling duty on an adjuster personally. Note this is the same definition that empties the CE requirement in cluster 2: § 20-281(5) doing the same work twice.
Free reproductions of the rule still print the pre-2024 text. Two of them agree with each other. Both are stale. Two agreeing mirrors are not the issuing publisher.
Read with the old definition — “any…entity authorized to represent an insurer with respect to a claim” — it captures the adjuster. The 2024 amendment added a second sentence:
“‘Agent’ has the same meaning as ‘Insurance producer’ as defined at A.R.S. § 20-281(5).”
⚠ So D.2 reaches PRODUCERS, not adjusters — and there is now no provision anywhere in A.A.C. Title 20 Ch. 6 imposing a claim-handling duty on an adjuster personally. Note this is the same definition that empties the CE requirement in cluster 2: § 20-281(5) doing the same work twice.
Free reproductions of the rule still print the pre-2024 text. Two of them agree with each other. Both are stale. Two agreeing mirrors are not the issuing publisher.
SUBSECTION C — A CONTENT STANDARD WITH NO PERIOD“The files shall contain all notes and work papers pertaining to the claim in such detail that pertinent events and the dates of the events can be reconstructed.” That is the entire subsection. ⚠ Arizona states no record retention period at all — not in the rule, not anywhere. A chart that prints one has supplied it. And R20-6-802, the rule number immediately after, is a tombstone: a placeholder for two lapsed emergency rulemakings. It requires nothing of anyone.
| Subsection D — six prohibitions with teeth | Cite | What it forbids |
|---|---|---|
| Disclosure | D.1 | ⚠ An affirmative duty to fully disclose to first party claimants all pertinent benefits and coverages. Silence is the violation |
| “Agent” | D.2 | Reaches producers after the 2024 amendment — not adjusters |
| Exhibit property | D.3 | No denial for failure to exhibit unless requested and refused “without a sound basis” |
| Time limits | D.4 | ⚠ A prejudice rule. Late notice does not relieve the insurer unless the failure prejudices the insurer’s rights |
| Releases | D.5 | No release “that extends beyond the subject matter that gave rise to the claim payment” |
| Partial payments | D.6 | ⚠ No release language on a partial-settlement check or draft. Advance payments are fine; the printing is not |
| The clocks — R20-6-801 | Days | Day type and cite |
|---|---|---|
| Acknowledge notice of a claim | 10 | WORKING — E.1. Unless payment is made inside the same 10 |
| Reply to other pertinent communications | 10 | WORKING — E.3 |
| Respond to a Department inquiry | 15 | WORKING — E.2 |
| Complete the investigation | 30 | ⚠ PLAIN — F. From notification of the claim, not from proof of loss |
| Accept or deny | 15 | WORKING — G.1.a, from properly executed proofs of loss |
| Notify that more time is needed | 15 | WORKING — G.1.b |
| Status letter, then recurring | 45 | PLAIN — G.1.b. Must state why, not merely that |
| Limitations warning — first party | 30 | PLAIN — G.4, unrepresented claimants only |
| Limitations warning — third party | 60 | ⚠ PLAIN — G.4. The longer period runs to the stranger claimant |
| Statutory payment clock | 30 | PLAIN — § 20-462, from an acceptable proof of loss |
PLAIN days: the 30-day investigation clock, the 45-day status cycle, the 30/60 limitations warnings and § 20-462WORKING days: acknowledgment, the Department response and the accept-or-deny decision
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The headline deadline is the one that is NOT in working days
⚠ An adjuster who assumes working days throughout gives themselves roughly two extra weeks on the investigation clock that Arizona has not given them. This is the single most operationally dangerous feature of the rule.
And the two clocks do not nest. F runs from notification; G.1 runs from properly executed proofs of loss. A claim reported on day 1 with proofs submitted on day 40 has an investigation clock that expired on day 31 and a decision clock that has not started.
§ 20-462 runs alongside both and is the one with money attached: unpaid at 30 plain days from an acceptable proof of loss and interest runs at the legal rate from the date the claim was received — not from day 31. Exempt: a denial made in good faith within those 30 days.
And the two clocks do not nest. F runs from notification; G.1 runs from properly executed proofs of loss. A claim reported on day 1 with proofs submitted on day 40 has an investigation clock that expired on day 31 and a decision clock that has not started.
§ 20-462 runs alongside both and is the one with money attached: unpaid at 30 plain days from an acceptable proof of loss and interest runs at the legal rate from the date the claim was received — not from day 31. Exempt: a denial made in good faith within those 30 days.
Arizona is a major first-party bad faith jurisdiction — and you personally cannot be sued.
The unfair claims statute gives nobody a private action (cluster 3). The common-law tort is where Arizona claim disputes actually live, and it is deep, settled and still developing. But it requires a contractual nexus — and that single requirement answers the question every adjuster asks about themselves.
The unfair claims statute gives nobody a private action (cluster 3). The common-law tort is where Arizona claim disputes actually live, and it is deep, settled and still developing. But it requires a contractual nexus — and that single requirement answers the question every adjuster asks about themselves.
| Case | Year | What it holds |
|---|---|---|
| Noble Docket 14531-PR | 1981 | The standard: absence of a reasonable basis for denying benefits, plus knowledge or reckless disregard of that absence |
| Rawlings Docket 18333-PR | 1986 | The implied covenant and equal consideration — “equal thought to the end that both the insured and the insurer shall be protected” |
| Deese Docket CV-91-0323-PR | 1992 | ⚠ A coverage denial is NOT a prerequisite. The covenant is breached “whether the carrier pays the claim or not.” A claim paid in full, late and badly, can be bad faith |
| Zilisch Docket CV-98-0535-PR | 2000 | ⚠ The controlling first-party standard. Fair debatability is necessary but not sufficient. “Coming up with an amount that is within the range of possibility is not an absolute defense” |
| Satamian Docket CV-23-0085-PR | 2024 | Reaffirmed accrual on final coverage denial, and confined final-judgment accrual to the third-party context |
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“It was fairly debatable” is only HALF the Arizona rule
A great many national courses teach that a fairly debatable claim cannot be bad faith. In Arizona that is necessary but not sufficient. Zilisch: the insurer must “play fairly with its insured,” and an insurer that lands on a defensible number by an indefensible process is still exposed.
⚠ Zilisch VACATED the Court of Appeals opinion below — so a secondary source describing that intermediate decision is describing a decision that no longer exists.
Punitive damages need the Rawlings “evil mind”, by clear and convincing evidence. Bad faith alone does not get punitives to a jury. Limitations: two years, from the original denial — and asking the insurer to reconsider does not restart it.
⚠ Zilisch VACATED the Court of Appeals opinion below — so a secondary source describing that intermediate decision is describing a decision that no longer exists.
Punitive damages need the Rawlings “evil mind”, by clear and convincing evidence. Bad faith alone does not get punitives to a jury. Limitations: two years, from the original denial — and asking the insurer to reconsider does not restart it.
✅ THE ADJUSTER CANNOT BE SUED PERSONALLY
⚠ BUT THE 180-DAY TRAP IS REAL
Meineke (1 CA-CV 98-0623, 13 July 1999) — an independent adjusting company “owes no independent duty to the insured”; its obligation “is measured by the contract between the adjuster and the insurer.”
Wagner (1 CA-CV 24-0562, 7 January 2026) — “a contractual nexus is a necessary element to any bad faith claim.”
Individual adjuster, independent firm and TPA alike. Exposure lands on the insurer, vicariously. Your personal exposure is REGULATORY, not civil.
Wagner (1 CA-CV 24-0562, 7 January 2026) — “a contractual nexus is a necessary element to any bad faith claim.”
Individual adjuster, independent firm and TPA alike. Exposure lands on the insurer, vicariously. Your personal exposure is REGULATORY, not civil.
Wagner also held the municipal risk retention pool “is a public entity for purposes of A.R.S. § 12-821.01,” so the claims were time-barred for failure to serve a notice of claim within 180 days.
⚠ If a city, town, county, school district or their risk pool is anywhere in the claim, the deadline is 180 DAYS — not the two-year bad-faith period. Tracking only the tort clock on such a file is wrong by a factor of four.
And a third-party claimant has no direct bad-faith action against the insurer at all. The duty runs to the insured.
⚠ If a city, town, county, school district or their risk pool is anywhere in the claim, the deadline is 180 DAYS — not the two-year bad-faith period. Tracking only the tort clock on such a file is wrong by a factor of four.
And a third-party claimant has no direct bad-faith action against the insurer at all. The duty runs to the insured.
THE NUMBERS ARIZONA DOES NOT HAVEThis is the fastest way to get an Arizona question wrong: supplying a national default for a figure Arizona leaves blank. No passing score. No exam fee. No record retention period. No fraud reporting deadline. No homeowners cancellation notice period. No total-loss percentage. No comparative negligence bar. No valued policy law. No matching rule. No PIP. No guaranty net worth exclusion.
| Automobile | Arizona | The trap |
|---|---|---|
| System | Tort | No PIP, no mandatory med-pay, no tort threshold — there is nothing to threshold |
| Liability minimums | 25/50/15 | From 1 July 2020; previously 15/30/10. The date is written inside § 28-4009 |
| Comparative negligence | PURE | ⚠ No 50% bar and no 51% bar. A claimant 95% at fault still recovers 5% |
| Joint and several liability | Abolished | Several only; fault apportioned across parties and nonparties as a whole at one time. Three carve-outs: in concert, agent or servant, FELA |
| UIM trigger | Damages | ⚠ Tortfeasor’s limits less than the total damages — not difference-in-limits |
| Stacking | Default | ⚠ Permitted unless the insurer expressly limits it in the policy AND gives the selection notice — Franklin (2023). Both, not either |
| Selection notice | 30 days | In the policy, or in writing within 30 days of notice of the accident. Both routes survive |
| Salvage trigger | — | ⚠ No percentage, and expressly subjective — what the owner or insurer “considers uneconomical to repair.” Salvage title in 30 days |
| Property, guaranty, fraud, comp | Arizona | The trap |
|---|---|---|
| Standard fire policy | NY 1943 | Incorporated by reference as to all provisions and the sequence thereof — Arizona prints no form of its own |
| Valued policy law | None | Proved by enumerating §§ 20-1501 to 20-1510. A total fire loss is adjusted, not paid at the face amount |
| Matching | None | Not in the fire article, not in the rule. “Like kind and quality” appears only in the automobile total-loss provision |
| Labor depreciation | Barred | ⚠ Walker (2022) — but only where the policy adopts replacement cost less depreciation. State both halves |
| Time to sue | 6 years | Default for a written contract — and it may be contractually shortened, subject to an unjust-forfeiture check |
| Homeowners cancellation | — | ⚠ No statutory notice period. § 20-1653 fixes what the notice must say, never when. Nonrenewal is 30 days |
| Guaranty cap / deductible | $300k / $100 | ⚠ Arizona kept the $100 deductible; comp claims sit outside the cap; no net worth exclusion |
| Fraud reporting | No clock | ⚠ The duty is mandatory — “shall send” — with no deadline anywhere |
| Fraud warning | 12 pt | ⚠ Required on claim forms only, not applications. § 20-466.03 |
| Comp maximum | $6,131.00 | ⚠ MONTHLY average wage for injuries in 2026 — Arizona has no weekly maximum. Keyed to the date of injury |
| Comp carrier decision | 21 days | ⚠ From COMMISSION notification. Miss it and the claim is paid as if accepted |
Two acts rewrite the adjuster article on 12 September 2026 — and no code source shows a word of them.
Arizona’s general effective date for the 2026 regular session is 12 September 2026. Two acts amending Article 3.2 were signed in April and June 2026. They are law. They are not in the code, because they have not commenced — so no publisher, mirror or secondary summary carries them. The only route to them is the session laws.
Arizona’s general effective date for the 2026 regular session is 12 September 2026. Two acts amending Article 3.2 were signed in April and June 2026. They are law. They are not in the code, because they have not commenced — so no publisher, mirror or secondary summary carries them. The only route to them is the session laws.
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Arizona publishes NO statutory history lines — and that is why this matters
The Legislature’s own section pages print the text and nothing else: no source note, no amendment history, no effective-date stamp. You cannot date an Arizona figure from the section it sits in.
⚠ A currency check performed against the Arizona statute — however official the source — would report that Arizona’s adjuster law had not changed. The code is not wrong. The amendments simply are not in force yet.
The lesson generalizes: ask what the CURRENT session did and when it takes effect. An act passed in June and effective in September is invisible to every code source in August.
⚠ A currency check performed against the Arizona statute — however official the source — would report that Arizona’s adjuster law had not changed. The code is not wrong. The amendments simply are not in force yet.
The lesson generalizes: ask what the CURRENT session did and when it takes effect. An act passed in June and effective in September is invisible to every code source in August.
🌪 CHAPTER 157 (SB 1206) — storm claims
💼 CHAPTER 11 (SB 1415) — § 20-321.03
Signed 19 June 2026. Amends §§ 20-321, 20-321.02 and 32-1158.02. Adds a definition, expands who is an adjuster, and imposes the first statutory conduct rules ever on Arizona adjusters — then mirrors them on the contractor side.
Signed 2 April 2026. Adds a whole new section — a narrow, time-limited licensing window for Arizona-resident salaried employee adjusters who hold another state’s designated home state license. It closes on 30 June 2027.
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A new definition at paragraph (1) renumbers the ENTIRE definitions section
§ 20-321(1), NEW: “Adjust means to investigate or negotiate the settlement of a claim arising pursuant to a property and casualty insurance contract.”
Inserting it at (1) pushes “Adjuster” from (1) to (2), and everything after it down one.
⚠ Every pin cite into § 20-321 written before 12 September 2026 is off by one afterward — including the workers’ compensation exclusion, which moves from § 20-321(1)(b)(ix) to § 20-321(2)(b)(ix). The substance does not move. The address does.
The session supplies its own example of the hazard: new § 20-321.03, enacted by the other act, cross-references the pre-renumbering citation.
Inserting it at (1) pushes “Adjuster” from (1) to (2), and everything after it down one.
⚠ Every pin cite into § 20-321 written before 12 September 2026 is off by one afterward — including the workers’ compensation exclusion, which moves from § 20-321(1)(b)(ix) to § 20-321(2)(b)(ix). The substance does not move. The address does.
The session supplies its own example of the hazard: new § 20-321.03, enacted by the other act, cross-references the pre-renumbering citation.
AND THE DEFINITION OF “ADJUSTER” GAINS A THIRD LIMBNew (a)(iii) reaches a person who “directly or indirectly solicits business from, investigates or advises an insured about claims… for a person that performs services pursuant to item (i).” This sweeps the solicitor into the license. Knock doors after a hailstorm, canvass storm damage or “advise” insureds on behalf of an adjusting operation and you are an adjuster from 12 September 2026. The nine exclusions at (b)(i)–(ix) are unchanged, subject only to the renumbering.
🔒 THREE NEW CONDUCT RULES — § 20-321.02(B)–(D)
(B) NO SOLICITING AT THE LOSS. An adjuster may not propose that they represent the insured while a loss-producing occurrence is continuing at the premises, or while the fire department or another public safety service is engaged in an emergency response there
(C) NO PARTICIPATING IN THE REPAIR. Not directly, not indirectly, not as contractor or subcontractor, in the restoration, reconstruction or repair of property that is the subject of a claim the adjuster adjusted
(D) NO ENDORSING THE INSURED’S CHECK. An adjuster may not endorse payment instruments issued to an insured without the insured’s direct endorsement and signature
⚠ Before this act Arizona imposed essentially NO conduct rules on adjusters — Article 7 of the A.A.C. is a graveyard and R20-6-801 binds insurers
🔨 THE SAME ACT CLOSES IT FROM THE CONTRACTOR SIDE — § 32-1158.02
(L) A post-storm contractor “shall not also act as an adjuster on behalf of the insured for the claim” — it previously barred only negotiating
(J) No deductible inducements — may not advertise to pay, issue payment for or promise to pay any deductible, or issue any rebate deductible
(O) NEW — may not propose that a person sign an agreement while a loss-producing occurrence is continuing or a public safety response is under way. The exact mirror of § 20-321.02(B)
Retained: 72-hour cancellation after a denial · four business days to cancel for any reason · refund within 10 days · down payment capped at 50%
READ THEM TOGETHER AND THE DESIGN IS OBVIOUSArizona is regulating the storm-chasing economy from both ends at once — the adjuster who solicits at the fire, and the roofer who does. The prohibition is written twice, in two different titles, in nearly identical words. Neither profession can do what the other is barred from doing.
| § 20-321.03 — the window, and it has a hard door at both ends | Figure | Note |
|---|---|---|
| Foreign designated home state license held before | 1 Jan 2026 | Must have been active then, and currently in good standing |
| Application, fee and fingerprints by | 30 Jun 2027 | § 20-285(E). After that the route is gone |
| Arizona examination | Waived | Provided the foreign license was earned by passing a state-approved examination |
| Who may use it | — | A salaried employee of an insurer or managing general agent, and an Arizona resident |
| Scope of the license | — | ⚠ Salaried employee work only. May not adjust on behalf of an insured, nor for an insurer in any other capacity |
| How long it lasts | — | ⚠ Valid and renewable only until the person ceases to adjust as a salaried employee. Leave the role and a full license is required |
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Why this section exists — it repairs a problem Arizona’s own exemption created
Arizona exempts staff adjusters from licensing (cluster 1). So an Arizona-resident staff adjuster has no home state license — and other states, which do license staff adjusters, will not issue a non-resident license to someone without one. Those adjusters were therefore obliged to designate some other state as their home state and qualify there.
§ 20-321.03 lets them convert that foreign license into a genuine Arizona license without re-examination, so Arizona can finally become their home state.
⚠ Note what it does NOT do. It creates no general designated home state credential for residents of non-licensing states. It runs the other way. And it is not a general exam waiver — the § 20-321.01(C)(3) designation route remains the only standing way to skip the Arizona examination.
§ 20-321.03 lets them convert that foreign license into a genuine Arizona license without re-examination, so Arizona can finally become their home state.
⚠ Note what it does NOT do. It creates no general designated home state credential for residents of non-licensing states. It runs the other way. And it is not a general exam waiver — the § 20-321.01(C)(3) designation route remains the only standing way to skip the Arizona examination.
Adjust
New at § 20-321(1) — to investigate or negotiate the settlement of a P&C claim. Renumbers everything after it.
Adjuster
The single license, both sides of the claim. Moves from (1) to (2) on 12 September 2026.
Salaried employee
The staff exclusion — and it turns on pay not contingent on claim outcomes, not on employment status.
The scope clause
§ 20-321.02 — a closed list of sixteen. What is missing is as operative as what is on it.
Contractual nexus
The element bad faith requires and an adjuster does not have. No personal civil liability.
Exhaustion
Guaranty fund — payment of the limits, or a court adjudication that nothing is owed. A denial is not exhaustion.
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Top Exam Tips — Arizona Adjuster Regulations
1. ONE LICENSE, BOTH SIDES. There is no public adjuster credential in Arizona.
2. THE STAFF EXCLUSION TURNS ON PAY, NOT EMPLOYMENT. Contingent on claim outcomes and the exclusion is gone.
3. A PURE COMP ADJUSTER IS TRIPLE-EXCLUDED. No license, no claims rule, no tort.
4. NO CE, AND NO TEMPORARY LICENSE. Both are proved by reading a scope clause — § 20-289(C)(3) points at a chapter that cannot reach adjusters, and § 20-294 was never imported.
5. STATUTE = PATTERN. RULE = ONE ACT. Name the instrument before you answer.
6. § 20-461(D) BARS PRIVATE ACTIONS ON THE STATUTE AND THE RULE.
7. 30-DAY INVESTIGATION CLOCK = PLAIN DAYS. Acknowledgment and accept-or-deny are working days.
8. FAIR DEBATABILITY IS NECESSARY, NOT SUFFICIENT. Zilisch, not the national shortcut.
9. YOU CANNOT BE SUED PERSONALLY — but a municipal risk pool claim runs on 180 days.
10. PURE COMPARATIVE FAULT. No bar at any percentage.
11. NO NUMBER WHERE ARIZONA STATES NONE — passing score, exam fee, retention period, fraud deadline, homeowners cancellation notice, total-loss percentage.
12. 12 SEPTEMBER 2026 — a new definition renumbers § 20-321, solicitors become adjusters, and three conduct rules arrive.
2. THE STAFF EXCLUSION TURNS ON PAY, NOT EMPLOYMENT. Contingent on claim outcomes and the exclusion is gone.
3. A PURE COMP ADJUSTER IS TRIPLE-EXCLUDED. No license, no claims rule, no tort.
4. NO CE, AND NO TEMPORARY LICENSE. Both are proved by reading a scope clause — § 20-289(C)(3) points at a chapter that cannot reach adjusters, and § 20-294 was never imported.
5. STATUTE = PATTERN. RULE = ONE ACT. Name the instrument before you answer.
6. § 20-461(D) BARS PRIVATE ACTIONS ON THE STATUTE AND THE RULE.
7. 30-DAY INVESTIGATION CLOCK = PLAIN DAYS. Acknowledgment and accept-or-deny are working days.
8. FAIR DEBATABILITY IS NECESSARY, NOT SUFFICIENT. Zilisch, not the national shortcut.
9. YOU CANNOT BE SUED PERSONALLY — but a municipal risk pool claim runs on 180 days.
10. PURE COMPARATIVE FAULT. No bar at any percentage.
11. NO NUMBER WHERE ARIZONA STATES NONE — passing score, exam fee, retention period, fraud deadline, homeowners cancellation notice, total-loss percentage.
12. 12 SEPTEMBER 2026 — a new definition renumbers § 20-321, solicitors become adjusters, and three conduct rules arrive.
Ten Arizona fact patterns — the traps, not the definitions.
Each of these turns on a place where Arizona answers a national assumption backwards, or where the answer lives in an instrument the question does not name. Read the feedback even when you are right.
Each of these turns on a place where Arizona answers a national assumption backwards, or where the answer lives in an instrument the question does not name. Read the feedback even when you are right.
Like learning this way? There's a whole library of them.
If the old manual you inherited from the office breakroom isn't cutting it and this format fits how your brain actually works, you'll want the rest. There are 56 Interactive Mind Maps like this one in the TESTivity Platinum Insurance Adjuster package — covering the full curriculum, right alongside the practice questions, exam simulators, and study guides.
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