Insurance License Types By State: A Practical Guide for Agencies

Insurance licensing in the United States operates under 50 separate state regulatory systems. There is no federal insurance license. The NAIC model regulation provides a framework that 38 states have adopted with modifications, but the remaining 12 states - including California, New York, and Florida - maintain distinct licensing structures, exam requirements, and renewal rules. An agency placing business in multiple states must comply with each state's requirements independently.

This guide covers the main license types, how they differ by state, the P&C vs. L&H vs. variable products distinction, surplus lines and adjuster licensing, and how multi-line agencies should structure their licenses.

Key Takeaways

• Most states use a unified "producer" license rather than separate "agent" and "broker" designations, following NAIC Producer Licensing Model Act (PLMA) structure.
• The P&C license and L&H license are separate in most states. Selling both lines requires both licenses.
• Surplus lines licensing requires a separate license in most states and involves additional compliance obligations including diligent search documentation.
• Adjuster licensing varies widely: most states exempt staff adjusters from licensing but require independent adjusters to hold a license.
• California, New York, and Florida each have licensing structures that differ materially from the NAIC model. Agencies operating in these states need state-specific procedures.
• Continuing education requirements - typically 24 CE hours per 2-year renewal cycle - vary by state and by license type.

The Main Insurance License Types

Producer / Agent License

The producer license is the most common insurance license type. Under the NAIC Producer Licensing Model Act, a "producer" includes anyone who sells, solicits, or negotiates insurance. In states following the NAIC model, the producer license has replaced the older separate "agent" and "broker" designations.

A producer license is specific to a line of authority. Most states issue separate lines of authority within the producer license:

• Property and casualty (P&C)
• Life and health (L&H)
• Life only
• Health only
• Personal lines (a subset of P&C, available in some states for agents selling only personal auto and homeowners)

To sell life insurance and property insurance in the same state, the producer typically needs both the L&H line of authority and the P&C line of authority - either under a single producer license or as separate licenses depending on the state.

States that retained separate agent and broker licenses. A minority of states, including California and New York, maintain a distinction between agents (who represent insurers) and brokers (who represent insureds). In California, a fire and casualty broker-agent license covers most P&C lines, while a separate life-only agent or accident and health agent license is required for those lines. In New York, broker and agent licenses are separate, and an agent license requires an appointment from a carrier while a broker license does not.

Broker License

In states that distinguish between agents and brokers, the broker license allows the licensee to represent insureds in placing coverage with multiple carriers rather than representing a single carrier as an agent. The broker carries a fiduciary duty to the client that is generally higher than an agent's duty to a carrier-appointed agent.

In NAIC model states, the producer license encompasses both agent and broker functions. The fiduciary duty analysis depends on state law and the nature of the relationship, not the license title.

Surplus Lines License / Broker License

Surplus lines insurance - coverage placed with non-admitted carriers - requires a separate license in most states beyond the standard producer license. The surplus lines license authorizes the licensee to place coverage with non-admitted markets when the risk cannot be placed in the admitted market.

NAIC model states. Most NAIC model states require a surplus lines producer license or endorsement in addition to the standard producer license. The licensee must conduct a "diligent search" of the admitted market before placing a risk on a surplus lines basis - typically documented by declinations from three admitted carriers, though the number varies by state.

California. California requires a separate surplus lines broker license (California Insurance Code 1765). The exam is separate from the standard fire and casualty broker-agent exam. California surplus lines brokers must also be registered with the Surplus Line Association of California (SLAC), which processes surplus lines transactions and collects the surplus lines tax.

Texas. Texas does not require a separate surplus lines license - instead, surplus lines brokers must register with the Surplus Lines Stamping Office of Texas (SLTX). Registration requires holding a standard Texas property and casualty license plus meeting SLTX-specific requirements.

New York. New York requires a separate excess line broker license (New York Insurance Law Article 21). The excess lines broker must conduct a diligent search and file stamping fees with the Excess Line Association of New York (ELANY).

Florida. Florida requires a surplus lines agent license (Florida Statute 626.914), which is separate from the standard 2-20 all-lines agent license or 2-14 life and health license.

Adjuster License

Adjuster licenses are required for individuals who investigate, negotiate, and settle insurance claims on behalf of insurers. Adjuster licensing is one of the most state-specific areas of insurance licensing - requirements vary dramatically across states.

Staff adjuster vs. independent adjuster. A staff adjuster is an employee of an insurance carrier who adjusts claims for that carrier. An independent adjuster (IA) is a contractor who adjusts claims for multiple carriers under contract.

Most states exempt staff adjusters from licensing requirements on the theory that the carrier supervises and is responsible for their employees. Independent adjusters are required to hold a license in most states because they operate without direct carrier supervision.

States that license staff adjusters. Florida, California, New York, and several other states require staff adjusters to hold a license regardless of employment status. Agencies and third-party administrators employing in-house claims staff in these states must verify adjuster licensing requirements.

Public adjuster license. A public adjuster represents the insured (not the insurer) in a claim. Most states require a separate public adjuster license, which carries additional regulatory requirements regarding contract language, fees, and solicitation restrictions.

Catastrophe (CAT) adjuster licensing. After major catastrophes, states often implement emergency licensing provisions for out-of-state adjusters. Florida, for example, issues emergency adjuster licenses during declared state of emergencies. Agencies and TPAs deploying adjusters after catastrophes need to track these state-specific emergency provisions.

Consultant License

An insurance consultant provides advice and analysis about insurance coverage for a fee, without selling insurance. The consultant license is separate from the producer license in most states that recognize it.

Not all states have a consultant license category. In states without a consultant license, consultants who do not sell insurance may still need a producer license if their activities constitute "negotiating" insurance - a term broadly interpreted in some states.

Consultants who charge fees for coverage analysis, claims assistance, or risk management advice without also placing coverage should verify whether their state's consultant license structure covers their activities or whether a producer license is required.

Managing General Agent (MGA) License

A managing general agent is an entity that underwrites and manages business on behalf of an insurer, with authority to bind coverage, issue policies, and sometimes handle claims. MGA licensing requirements vary by state.

Most states require MGAs to be licensed as insurance producers with the appropriate line of authority. Some states - including California (California Insurance Code 769.80) - have specific MGA licensing or registration requirements in addition to the standard producer license.

MGAs operating in multiple states need to verify MGA-specific requirements in each state, as some states treat MGA activities as requiring additional authority beyond standard producer licensing.

Third-Party Administrator (TPA) License

A TPA administers insurance benefit programs on behalf of insurers or self-insured employers - handling claims, processing enrollment, and managing plan documents. TPA licensing requirements exist in approximately 30 states.

In states with TPA licensing, the TPA must register with the state insurance department and meet financial requirements, including minimum capital or bond amounts. California requires TPA registration under California Insurance Code 1759. Texas requires TPA registration under Texas Insurance Code Chapter 4151.

TPAs operating across state lines need to verify which states require licensing and whether any federal exemptions apply for certain ERISA-governed benefit programs.

P&C License vs. L&H License vs. Variable Products License

These three license categories cover different product types and require separate licensing in most states.

Property and Casualty (P&C) License. Authorizes the sale of property insurance (fire, allied lines, commercial property, homeowners, commercial auto, inland marine) and casualty insurance (general liability, workers compensation, professional liability, commercial auto liability). The P&C license is typically a single line of authority under the producer license.

Life and Health (L&H) License. Authorizes the sale of life insurance, health insurance, disability insurance, and annuities. In some states, the L&H license is a combined line of authority. In others - including California - life and health are separate lines of authority requiring separate study and exams.

Variable Products License. Variable annuities and variable life insurance are securities as well as insurance products. Selling them requires both:

1. A state insurance license with variable products authority (usually an additional exam beyond the standard L&H license), and
2. A FINRA Series 6 or Series 7 securities registration with the broker-dealer.

Agents selling variable products without the appropriate securities registration face sanctions from both state insurance departments and FINRA. The dual licensing requirement is one of the most common compliance gaps in agencies that cross-sell variable annuities alongside standard life and health products.

How States Differ: NAIC Model vs. Non-Model States

The NAIC Producer Licensing Model Act (PLMA) has been adopted in 38 states and creates a relatively uniform structure: a single producer license with multiple lines of authority, reciprocal licensing for non-residents, and standardized CE requirements.

Reciprocal non-resident licensing. Under the NAIC model, a producer licensed in their home state can obtain a non-resident license in another NAIC model state without taking a separate exam - the non-resident state recognizes the home state exam. This significantly simplifies multi-state licensing for agencies operating in NAIC model states.

Non-model states. California, New York, and Florida each have licensing structures that differ from the NAIC model. California uses broker-agent designations and does not offer reciprocal non-resident licensing in the same manner. New York separates agent and broker licensing. Florida has a complex tiered license structure (2-20 all-lines, 4-40 customer representative, 2-14 life and health, and others).

Agencies expanding into California, New York, or Florida for the first time face a significantly different licensing process than in NAIC model states. Plan for additional exam requirements, different application procedures, and distinct renewal timelines.

Surplus Lines: Diligent Search Requirements

The diligent search requirement for surplus lines placement is state-specific but follows a consistent logic: the producer must attempt to place the risk with the admitted market before resorting to surplus lines.

Most states require documented declinations from a minimum number of admitted carriers - typically two to three. The specific number and documentation requirements vary:

• California: requires documentation showing the admitted market was reasonably searched. SLAC reviews diligent search documentation on filing.
• Texas: SLTX requires a diligent effort certification on each transaction.
• New York: ELANY requires specific declination forms and documentation of the search.
• Florida: requires declinations from at least three admitted carriers for most risks.

Agencies placing surplus lines must maintain diligent search documentation in the client file. State insurance department audits routinely check surplus lines files for diligent search compliance. Deficient documentation can result in fines and license sanctions under anti-rebating and placement regulations.

Multi-Line Agencies: Structuring Your Licenses

An agency that wants to sell P&C, L&H, and variable products, and also place surplus lines, in multiple states needs a structured licensing plan.

Step 1: Identify all states where you place business. Resident licensing is required in your home state. Non-resident licensing is required in every other state where you sell, solicit, or negotiate insurance - including phone and email solicitation of clients in that state.

Step 2: Identify required lines of authority per state. P&C and L&H are typically separate. Surplus lines require a separate license or registration. Variable products require an additional exam and securities registration.

Step 3: use NAIC reciprocity where available. For the 38 NAIC model states, reciprocal non-resident licensing eliminates the need for separate state exams. Complete the exam in your home state and apply for reciprocal non-resident licenses in the other states.

Step 4: Build a CE tracking system. Continuing education requirements vary by state and line of authority - typically 24 hours per 2-year renewal cycle, with ethics requirements in most states. Tracking CE deadlines across multiple states and license types without a system creates renewal lapses. A license that lapses mid-year requires reinstatement, which in most states means re-examination.

Step 5: Track anti-rebating rules by state. Anti-rebating statutes prohibit producers from giving anything of value as an inducement to purchase insurance. The specific prohibitions, exceptions, and penalties vary by state. Multi-state agencies need to train staff on state-specific anti-rebating rules, particularly as they relate to client gifts, fee-sharing, and promotional materials.

Frequently Asked Questions

What are the main types of insurance licenses?

The main insurance license types are: producer/agent license (authorizes selling insurance, with separate lines of authority for P&C, L&H, and variable products), broker license (in states that distinguish agents from brokers), surplus lines license or registration (for non-admitted market placements), adjuster license (for claims professionals, with staff adjuster exemptions in most states), consultant license (for fee-based advisory services), MGA license (for entities underwriting on behalf of carriers), and TPA license (for benefit program administrators). The specific requirements differ by state.

Do you need a separate license to sell surplus lines insurance?

Yes, in most states. A standard producer license does not authorize surplus lines placements. Most states require a separate surplus lines producer license or endorsement. California requires a surplus lines broker license plus SLAC registration. Texas requires SLTX registration rather than a separate license. New York requires a separate excess line broker license. Florida requires a surplus lines agent license (separate from the standard 2-20 license).

What is the difference between a P&C license and an L&H license?

A P&C (property and casualty) license authorizes the sale of property insurance, commercial auto, GL, workers compensation, and related casualty lines. An L&H (life and health) license authorizes the sale of life insurance, health insurance, disability, and annuities. These are separate lines of authority in most states, requiring separate exams and carrying separate CE requirements. Agents who sell both product types need both licenses.

Are staff adjusters required to hold an adjuster license?

In most states, staff adjusters who are employees of an insurance carrier are exempt from adjuster licensing requirements. However, California, Florida, New York, and a handful of other states require staff adjusters to hold a license regardless of employment status. Independent adjusters are required to hold a license in most states. Public adjusters - who represent insureds rather than carriers - require a separate public adjuster license in virtually all states.

How does reciprocal non-resident licensing work?

Under the NAIC Producer Licensing Model Act, a producer licensed in their home state can obtain a non-resident license in another NAIC model state without sitting for a separate exam. The non-resident state accepts the home state's exam and licensing. This applies to 38 states. California, New York, and Florida do not offer full reciprocity in the same manner - producers entering those states typically face additional requirements.

What continuing education is required to maintain an insurance license?

Most states require 24 CE hours per 2-year renewal cycle, including 3 hours of ethics. Requirements vary by state and line of authority. California requires 24 CE hours for most license types, with specific requirements for certain lines including long-term care. New York requires 15 CE credits per 2-year cycle for most lines. Texas requires 24 CE hours per 2-year cycle. Variable products agents must also satisfy FINRA CE requirements through the Regulatory Element and Firm Element programs.

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For the regulatory obligations that arise once licensing is in place - including fiduciary standards, disclosure requirements, and market conduct examination preparation - see post #461. For compliance tracking workflows across multi-state operations, see post #463.

Written by Javier Sanz, Founder of BrokerageAudit. Last updated April 2026.

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