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Massachusetts Board Moves to Reaffirm Licensed-Appraiser Requirement for Repair Shops

Shops would still need a licensed appraiser on staff or under contract, even after state agency dropped that condition for registering.

man writing in a notebook in front of a damaged front of a car
Massachusetts' Auto Damage Appraiser Licensing Board plans to vote July 14 on a rule confirming that collision repair shops must keep a licensed appraiser on staff or under contract, despite a separate registration change.

Massachusetts' Auto Damage Appraiser Licensing Board plans to vote on a rule that would reaffirm that collision repair shops must keep a licensed appraiser on staff or under contract, even though a separate state agency no longer requires this for shop registration.

The Auto Damage Appraiser Licensing Board (ADALB) is scheduled to vote on Proposed Advisory Ruling 2026-X at its meeting on July 14, 2026, according to the ruling posted on the board's website. The board is taking public comments on the proposal before that vote.

The Massachusetts Division of Standards, which handles shop registrations under state law, stopped requiring shops to employ a licensed appraiser in order to register. But that change only affects registration. It doesn't cancel the separate rules ADALB has always had. Repair shops, insurers, and licensed appraisers must still follow ADALB's rules, including the requirement that shops keep a licensed appraiser on staff or under contract, no matter what the Division of Standards now requires for registration.

The ruling applies only to cases where an insurer is appraising vehicle damage that could lead to a claim payment, according to the ruling document.

The board says shops still need a licensed appraiser

The board pointed to its existing rule, which says "all repair shops shall maintain one or more licensed appraisers in their employment for the purpose of preparing motor vehicle damage appraisals," according to the ruling text. The board states that two related sections of its regulation "remain fully enforceable" regardless of the Division of Standards' registration practices, the document states.

The ruling also spells out what counts as compliance for shops without an appraiser on staff. A shop can meet the requirement by hiring a licensed appraiser as a subcontractor, "provided the appraiser is directly responsible for preparing and negotiating the appraisal," according to the ruling.

What counts as a violation

The proposal also covers misrepresentation. If a shop or insurer claims an appraisal was prepared by a licensed appraiser when it wasn't, that counts as "noncompliant activity subject to enforcement for unlicensed appraisal conduct or misrepresentation of appraiser employment," the document states.

The ruling also says licensed appraisers "shall not knowingly negotiate repairs with unlicensed individuals or unregistered repair shops," according to the proposed text.

If the board adopts the rule on July 14, it would take effect once posted on ADALB's website. Under the board's rules, not complying "may result in fines and penalties as provided by law," the document states.