Guidance Comes in Form of Bulletin #INS 25-031-AB
The New Hampshire Insurance Department (NHID) has issued a bulletin clarifying insurers’ obligations when using virtual claims adjustment systems to assess automobile damage. The guidance comes in response to a growing number of insurers relying on photo and video submissions from consumers or repair shops rather than conducting in-person inspections.
“The implementation of virtual claims systems can improve efficiency, but it must not come at the expense of fairness or thoroughness in the claims process,” said Insurance Commissioner DJ Bettencourt. “Additionally, Granite Staters should not be denied the right to an in-person inspection simply because they initially submitted photos or videos.”
Under the Unfair Claims Settlement Practices (UCSP) provisions of the state’s Unfair Insurance Trade Practices law (RSA 417:4, XV), insurers are required to promptly and reasonably investigate and settle claims fairly once liability is clear. While virtual adjustment tools can expedite the process, they may not always capture the full extent of a vehicle’s damage. To remain in compliance with the UCSP, insurers must offer an in-person inspection within a reasonable timeframe if the consumer requests one. Insurers may not deny such a request based solely on a consumer’s prior participation in a virtual assessment.
Unreasonable delays in providing requested in-person inspections may also constitute a violation of the duty to promptly and reasonably investigate claims under RSA 417:4, XV(a)(3).
“Ensuring transparency and timeliness in the claims process is essential to protecting consumers,” said Deputy Insurance Commissioner Keith Nyhan. “These clarifications reinforce that insurers cannot rely solely on virtual tools if doing so limits a consumer’s right to a fair investigation.”
The full bulletin, Docket #INS 25-031-AB, can be viewed at https://mm.nh.gov/files/uploads/nhid/documents/20250414-ins-25-031-ab.pdf 
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