Regulating the Pet Insurance Market: An Overview of Florida’s New Statutory Framework

by Mallory Lizana  The Florida Bar Journal Vol. 100, No. 3 pg. 40  May/June 2026

he pet insurance industry in the U.S. has experienced substantial growth over the past several years, evolving from a niche product into a multibillion-dollar market, with gross written premiums for pet health insurance surpassing $4.7 billion nationwide in 2024, a significant rise from just a few years earlier.^[1] Although the rapid expansion seen during the immediate post-pandemic period has moderated, the industry continues to grow at a consistent double-digit rate.^[2] While there is likely a combination of factors sustaining this upward trajectory, the main causes include product innovation, the entry of new insurers, and the strengthening human-animal bond that has increasingly positioned pets as members of the family in much of the public’s eye.

Alongside this financial growth, the number of insured pets has also risen sharply. By the end of 2024, approximately 6.4 million pets in the U.S. were covered by insurance policies, more than double the number insured in 2020.^[3] Dogs account for the majority of insured animals, followed by cats, with coverage for other species remaining comparatively limited.^[4] Despite this expansion, pet insurance remains far from universal, and its structure, exclusions, and reimbursement mechanisms are often unfamiliar to consumers encountering it for the first time.

Pet insurance generally functions as a form of health coverage for animals, reimbursing owners for non-routine veterinary expenses related to accidents and illnesses, such as emergency treatment, chronic disease management, or surgical care.^[5] In contrast, pet wellness programs focus on budgeting for expected veterinary services, including examinations, vaccinations, and preventive treatments.^[6] While these programs can assist with cost predictability, they are not insurance products and may not ultimately reduce overall expenditures.^[7] The coexistence of insurance policies and wellness plans, which are sometimes offered together and sometimes separately, has contributed to consumer confusion regarding coverage, costs, and legal protections.

Despite the industry’s size and its close resemblance to human health insurance in practice, pet insurance is generally regulated as a form of property insurance under state law, if it is regulated at all.^[8] Historically, few states have enacted statutes tailored specifically to pet insurance, resulting in inconsistent standards for disclosures, terminology, and sales practices.^[9] This regulatory gap has drawn increasing attention as consumer complaints and policy disputes have become more common in a growing market.^[10]

In response to these concerns, the National Association of Insurance Commissioners (NAIC) developed the Pet Insurance Model Act in 2022, intended to provide states with a framework for regulating pet insurance as a distinct product.^[11] The model emphasizes transparency, standardized definitions, disclosure of exclusions and waiting periods, differentiation between insurance and wellness programs, and training requirements for insurance producers.^[12] While the model act is freely available for adoption or modification, only a limited number of states have enacted comparable legislation to date.^[13]

Effective January 1, 2026, Florida became one of these limited number of states to enact legislation specifically regulating pet insurance as a distinct product. House Bill 655 (2025), with companion Senate Bill 1226 (2025), was enacted as Ch. 2025-11, following approval by the governor in April 2025.^[14] The legislation both created and amended provisions within Florida’s Insurance Code, primarily in F.S. Ch. 627, by amending F.S. §624.604 and F.S. §626.9541, and by creating F.S. §627.71545, dedicated exclusively to pet insurance.^[15]

Background: Pet Insurance and Regulatory Context

Pet insurance, more accurately described as “pet health insurance,” is designed to reimburse pet owners for certain veterinary expenses associated with accidents, illnesses, and, in some cases, preventive care.^[16] Coverage is most commonly available for dogs and cats, while other animals are generally categorized as exotic pets and typically require specialized policies offered by a smaller subset of insurers.^[17] Unlike human health insurance, pet insurance generally operates on a reimbursement model in which the pet owner pays the veterinarian at the time services are rendered and later submits a claim for covered expenses.^[18] Reimbursement is then issued after review and is subject to policy terms such as deductibles, reimbursement percentages, and coverage limits. Although some insurers offer direct payment arrangements with veterinary clinics, post-payment reimbursement remains the predominant approach.^[19]

Coverage options vary by insurer and policy type but typically fall into two broad categories: accident-only plans and comprehensive plans covering both accidents and illnesses.^[20] Accident-only plans tend to be less expensive and provide limited coverage for injuries resulting from events such as fractures or ingestion of foreign objects. Comprehensive plans generally cover a wider range of conditions, including chronic and serious illnesses subject to policy exclusions. Many insurers offer optional add-ons for routine or preventive care, though such coverage is not standard and often requires an additional premium.^[21] Pet insurance policies commonly exclude preexisting conditions, and premiums are determined by factors such as the pet’s age, breed, geographic location, deductible, and reimbursement level, with higher deductibles and lower reimbursement percentages generally resulting in lower premium costs.^[22]

Although pet insurance functions similarly to human health insurance in practice, it is legally classified as a form of property insurance because pets are considered property under the law.^[23] Pet insurance is not a standardized product, and policy terms, coverage scope, and exclusions can vary significantly among insurers.^[24] This lack of uniformity has contributed to consumer confusion and has played a role in calls for greater regulatory clarity as the market has expanded.

Pet wellness programs differ fundamentally from pet insurance, though the distinction is not always well understood by consumers. A pet wellness plan is not an insurance product but rather a financial arrangement intended to help pet owners manage the cost of routine and preventive veterinary care.^[25] These plans typically cover services such as physical examinations, vaccinations, routine laboratory testing, dental cleanings, parasite prevention, and spay or neuter procedures.^[26]

Wellness plans typically operate on a subscription or payment-plan basis, with pet owners paying a monthly or annual fee for access to a defined set of preventive services.^[27] Some wellness plans are offered as optional add-ons to pet insurance policies, while others are available as standalone programs through veterinary practices or animal hospital networks.^[28] Unlike pet insurance, wellness plans are often limited in scope and location, with many plans usable only at the specific veterinary clinic or network where they were purchased and providing no benefit for emergency or specialty care obtained elsewhere.^[29] Because they are structured as payment plans rather than risk-based insurance, wellness plans do not protect against unexpected or high-cost medical events.^[30]

A common source of consumer misunderstanding arises from the assumption that wellness plans function as insurance. Rather than transferring financial risk to an insurer, wellness plans spread the cost of anticipated services over time and may or may not produce overall cost savings depending on the services used and the plan’s pricing structure.^[31] Another common misconception is the belief that wellness plans can be used at any veterinary clinic or that they may be canceled without consequence at any time.^[32] Because wellness plans often cover services delivered early in the contract term, early cancellation may require the pet owner to pay for services already received or incur cancellation fees.^[33]

While wellness programs can play a valuable role in encouraging routine veterinary care and improving cost predictability, their similar marketing alongside pet insurance has contributed to confusion regarding coverage, consumer expectations, and regulatory treatment.

Florida’s Pet Insurance Law

To combat the confusion, the Florida Legislature enacted Florida’s Pet Insurance Law, Ch. 2025-11, which went into effect January 1, 2026.^[34] Oversight of the law is assigned to the Florida Office of Insurance Regulation (OIR), which ensures that insurers comply with the state’s insurance requirements and that both insurance products and wellness programs are administered transparently and fairly.^[35] The legislation formally recognizes coverage for pet accidents, illnesses, and diseases under Florida law, expanding the definition of property insurance to explicitly include pet coverage.^[36] This framework applies to all policies sold, solicited, or delivered within the state and establishes specific rules designed to protect consumers while facilitating the responsible sale of pet insurance.^[37]

As part of this law, F.S. §624.604 amends the definition of “property insurance” to explicitly include pet insurance coverage.^[38] The statute clarifies that property insurance may provide protection for pet accidents, illnesses, and diseases, either as a standalone policy or as incidental coverage within broader policies, such as a homeowner’s plan.^[39]

F.S. §626.9541, also enacted under Ch. 2025-11, addresses unfair or deceptive sales practices related to pet wellness programs.^[40] The statute prohibits agents from marketing wellness programs as insurance and requires that any wellness program sold alongside pet insurance be optional, separately priced, and entirely distinct from the insurance policy in terms, conditions, and benefits.^[41] Programs cannot duplicate coverage already provided by a policy and all advertising must be both clear and accurate.^[42]

The core regulatory framework is established in F.S. §627.71545, commonly called the Pet Insurance Act.^[43] Under this statute, pet insurers must disclose policy exclusions for chronic conditions, congenital anomalies, hereditary disorders, and preexisting conditions.^[44] Policies must explain deductibles, coinsurance, waiting periods, annual and lifetime limits, and claim calculation methods.^[45] Consumers are granted a 30-day “free-look” period during which they can return a policy for a full refund if no claims have been filed.^[46] Insurers must also clearly distinguish between the underwriting company and the brand used to market the policy.^[47]

To reduce ambiguity and disputes, F.S. §627.71545 mandates standardized statutory definitions for key terms such as “chronic condition,” “congenital anomaly or disorder,” “hereditary disorder,” “preexisting condition,” “orthopedic condition,” “pet insurance policy,” “renewal,” “veterinarian,” “waiting period,” and “wellness program.”^[48] These definitions must be included verbatim in policies and made accessible to policyholders, typically via insurer websites.^[49] The law also regulates preexisting conditions and waiting periods, allowing exclusions and up to 30-day waiting periods for certain conditions while prohibiting them for accidents.^[50] Waiting periods may be waived if a veterinary examination is completed, usually at the policyholder’s expense, and insurers cannot require examinations for policy renewal.^[51] Participation in wellness programs cannot affect eligibility for coverage.^[52]

To support these protections, F.S. §627.71545 also requires insurers to provide comprehensive training for agents and brokers.^[53] Training must cover distinctions between pet insurance and wellness programs, preexisting conditions, waiting periods, chronic and hereditary conditions, and other administrative topics such as rating, underwriting, and policy renewals.^[54] Agents must complete training before selling policies, and satisfaction of equivalent training requirements in other states may be recognized.^[55]

Although recently enacted, Ch. 2025-11 is already the subject of proposed legislative amendments aimed at refining its provisions. During the 2026 legislative session, S.B. 158 and its companion, H.B. 983, were filed to amend F.S. §627.71545.^[56] The proposed legislation would expand disclosure obligations by requiring pet insurers, at the time of policy issuance, to provide not only the existing insurer disclosure of important policy provisions, but also a written summary of key policy features in plain language, contact information for the Division of Consumer Services, and the address and customer service telephone number of the selling agent.^[57]

The bills also propose modifications to agent training requirements. Rather than placing the full burden on insurers to ensure agent training, the amendments would permit agents to rely on insurer-provided, policy-specific training standards and materials, and would require completion of a biennial two-hour training course on specified topics.^[58] Although these training standards would not automatically count toward an agent’s statutory continuing education requirements, approved courses could qualify for continuing education credit.^[59]

In addition, the proposed amendments would introduce an annual reporting requirement. Beginning March 1 of each year, authorized pet insurers would be required to file a report with the OIR detailing the number of policies issued, renewed, and canceled; aggregate premium and claims data; information concerning denials and rescissions and the reasons for each; data regarding waiting periods and exclusions; and information about wellness program offerings.^[60]

As of early February 2026, S.B. 158 has been approved by the Senate Banking and Insurance Committee and referred to the Appropriations Committee on Agriculture, Environment, and General Government.^[61] H.B. 983 has been filed and referred to the House Insurance and Banking Subcommittee.^[62] If enacted, these amendments would further refine Florida’s regulatory approach by increasing transparency, clarifying training standards, and enhancing regulatory oversight through structured data reporting.

Consumer and Market Considerations

The new law marks a meaningful shift in Florida’s approach to pet insurance, but its true effects are yet to be felt. On one hand, creating clear boundaries between insurance and wellness programs, along with standardized terminology, will certainly make the market easier to navigate. Consumers can feel more confident in their decisionmaking knowing that policy terms are consistent and that they can easily understand what is and isn’t covered. In theory, this could also help agents and insurers operate with greater clarity, thereby reducing disputes and confusion.

At the same time, there are practical challenges that come with these protections. Insurers will need to update policies, revise marketing materials, and train agents on the new rules, which could be resource-intensive, particularly for smaller companies. Compliance costs could also ripple into pricing or product availability, though it is difficult to predict exactly how insurers will adjust. Administrative tasks such as tracking waiting periods, preexisting conditions, and proper disclosures are more structured now, but they also represent a heavier burden than before. Some observers may question whether the law imposes too much oversight on an evolving market, and there may be gray areas that only experience and enforcement will clarify.

The proposed amendments suggest that the legislature is already calibrating the balance between consumer protection and regulatory burden. Requiring a standardized summary form and structured reporting could meaningfully improve transparency, but they also move the statute further into detailed administrative oversight. Whether that level of structure proves necessary will depend on how the market responds to the original law. If consumer confusion persists or complaints increase, additional disclosure and reporting may be justified. If, however, the existing framework operates smoothly, layering new requirements onto a recently enacted statute could create complexity before its initial effects are fully understood. The timing of these amendments, therefore, raises a practical question: How quickly should a developing regulatory scheme be refined before its real-world performance can be evaluated?

Even with these challenges, the law and its pending amendments represent a concrete step toward making the pet insurance market more transparent. While insurers and agents will need to adapt to meet the new requirements, consumers stand to benefit from clearer policies, more reliable coverage, and a better understanding of how insurance and wellness programs differ.

Final Observations and Other State Approaches

Florida’s new pet insurance law is not the first of its kind and is unlikely to be the last. The push for clearer pet insurance policies began in 2014 when California became the first state to pass legislation specifically regulating pet insurance.^[63] Other than California and Florida, only 12 additional states have adopted comprehensive pet insurance statutes, including: Delaware, Louisiana, Maine, Maryland, Mississippi, Montana, Nebraska, New Hampshire, Ohio, Pennsylvania, Vermont, and Washington.^[64] While the details vary, these laws generally require clear policy disclosures, a free-look period, limits on waiting periods for coverage, and explicit separation of wellness programs from insurance.^[65] Other states are also actively considering adopting similar measures. New Jersey has advanced a pet insurance act through committee, while New York, after an initial veto in 2024, is revisiting legislation to address consumer protections.^[66] Hawaii, Illinois, Massachusetts, and Rhode Island are also reviewing bills that would incorporate elements of the NAIC model.^[67]

In the national context, Florida’s law positions the state among those leading in both scope and detail. By combining standardized statutory definitions, explicit consumer protections, and clear guidance for wellness programs, the legislation offers a level of clarity and enforceability that many other states have yet to achieve. As more states consider similar frameworks, Florida’s approach may very well serve as a model for balancing regulatory oversight with the practical realities of a fast-expanding pet insurance market.

This column is submitted on behalf of the Animal Law Section, Scott Guarcello, chair, Macie Routa, editor, and Ralph A. DeMeo, special editor.