The Massachusetts Auto Damage Appraiser Licensing Board (ADALB) is moving to formally reaffirm that licensed appraisers remain mandatory for all insurance-related auto damage appraisals—regardless of recent changes to repair shop registration requirements. In a proposed advisory ruling open for public comment, the Board makes clear that its regulations under 212 CMR 2.00 continue to govern appraisal activity, even as the Division of Standards has eliminated a parallel licensing requirement for repair shop registration.
The ADALB is seeking public comment on the advisory ruling scheduled to be voted on at its July 14, 2026, meeting.
Division of Standards Change Does Not Affect ADALB Requirements
Both the ADALB and the Division of Standards, which govern different aspects of repair shop operations within the Commonwealth, operate independently from one another. The Massachusetts Division of Standards (DOS) administers motor vehicle repair shop registrations under M.G.L. c. 100A. Unlike the ADALB regulations, DOS no longer requires repair shops to employ a licensed motor vehicle damage appraiser as a condition of repair shop registration.
The proposed advisory ruling would emphasize that this change does not affect the requirements imposed by the Board’s regulations under 212 CMR 2.00.
Licensed Appraisers Still Required for Insurance-Related Appraisals
Under the proposal, any repair shop preparing appraisals, supplemental appraisals, expedited supplemental requests, or other insurance-related appraisal documents would still be required to comply with 212 CMR 2.04, including maintaining one or more licensed appraisers in its employment. The Board proposes to interpret “employment” broadly enough to include a licensed appraiser retained as a subcontractor, provided that appraiser is directly responsible for preparing and negotiating the appraisal.
The proposed ruling also addresses situations in which appraisals are attributed to licensed appraisers who were not directly involved in the appraisal process. According to the proposal, any repair shop or insurer representing an appraisal as having been prepared by a licensed appraiser when that appraiser did not personally prepare and negotiate the appraisal would be engaging in noncompliant conduct subject to enforcement. The Board states that such activity could constitute either unlicensed appraisal conduct or misrepresentation of appraiser employment.
Lastly, the proposed ruling would clarify that licensed and independent appraisers should not knowingly negotiate repairs with unlicensed individuals or unregistered repair shops.
Purpose of the Proposed Advisory Ruling
The main purpose of the advisory ruling is to reaffirm the continued applicability of 212 CMR 2.00 and clarify the responsibilities of appraisers, insurers, and registered repair shops. It also serves as a warning to repair shops and insurers that the Board’s requirements under 212 CMR 2.00 remain in effect and continue to govern appraisal activity notwithstanding recent changes to repair shop registration requirements under the Division of Standards.
The proposal appears aimed at ensuring that the Division of Standards’ decision to eliminate a licensed-appraiser requirement for repair shop registration is not interpreted as eliminating the separate licensing requirements governing insurance-related appraisal activities under the ADALB’s regulations.
For those individuals interested in reviewing the proposed ruling, it can be viewed below:
