9.3 Continuing Education, Renewal & Emergency Licensing

9.3 Continuing Education, Renewal & Emergency Licensing

Quick Reference: Texas adjuster licenses renew biennially (every two years) based on the licensee's birth date. Adjusters must complete 24 hours of approved Continuing Education (CE) every two years, with at least 3 hours in Ethics/Consumer Protection and at least 50% (12 hours) in a classroom or classroom-equivalent format. CE fines run $50 per deficient hour, capped at $500 per license type. A license expired 90 days or less may be renewed for the renewal fee plus an additional fee equal to one-half of it (TDI: $50 + $25). A license expired more than 90 days but less than one year may not be renewed at all — the adjuster must apply for a new license (no new exam required) and pay the license fee plus one-half of it. A license expired one year or more requires re-examination. Adjusters must notify TDI immediately of a change of address, name, or business name. In declared disasters, TDI issues Emergency Adjuster Licenses valid for 90 days (extendable to 180 days).

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Continuing Education (CE) Requirements (28 TAC § 19.1001 et seq.)

To ensure licensed adjusters maintain technical competence and stay current with evolving statutes, building codes, and court interpretations, the Texas Department of Insurance enforces mandatory Continuing Education (CE) standards under Title 28 of the Texas Administrative Code (28 TAC § 19.1001 et seq.) and TIC Chapter 4004.

┌────────────────────────────────────────────────────────────────────────┐
│                     TEXAS ADJUSTER CE ARCHITECTURE                     │
├────────────────────────────────────────────────────────────────────────┤
│  TOTAL REQUIREMENT: 24 Approved Hours every 2-Year Cycle               │
├────────────────────────────────────────────────────────────────────────┤
│  • Mandatory Ethics: At least 3 Hours in Ethics / Consumer Protection   │
│  • Delivery Format Mandate: At least 50% (12 Hours) must be            │
│    CLASSROOM or CLASSROOM-EQUIVALENT (interactive live webinars)       │
│  • Maximum Self-Study: No more than 50% (12 Hours) via asynchronous   │
│    self-study reading or online modules                                │
│  • Rollover Rule: Zero rollover; excess hours DO NOT carry forward     │
│  • Fine Rule: $50 per hour not completed by the expiration date,       │
│    capped at $500 per license type (terms expiring after 6/1/2018)    │
└────────────────────────────────────────────────────────────────────────┘

1. The 24-Hour Biennial Requirement

Every licensed adjuster—whether holding an All-Lines, Property and Casualty, or Workers' Compensation credential—must accumulate a minimum of 24 credit hours of TDI-approved continuing education during each two-year licensing period.

2. The 3-Hour Mandatory Ethics Component

Of the 24 required hours, at least three (3) credit hours must specifically cover Ethics or Consumer Protection. General claims adjusting courses do not satisfy this requirement; the course must be explicitly certified by TDI as fulfilling the ethics topic.

3. The 50% Classroom / Classroom-Equivalent Rule

Texas strictly regulates CE course delivery methods to prevent passive credentialing:

• At least twelve (12) hours (50% of the total) must be earned in a classroom or classroom-equivalent setting.
• What Qualifies as Classroom-Equivalent? Live, interactive webinars where attendance is actively tracked, real-time polling questions are administered, and attendees can interact directly with the instructor qualify as classroom-equivalent.
• Self-Study Limit: Asynchronous self-study online courses (where a student reads text and completes a quiz at their own pace) are capped at a maximum of 12 hours per cycle.

4. Course Rollover & Compliance Tracking

• No Carryover of Excess Hours: If an energetic adjuster completes 36 CE hours during a two-year cycle, the surplus 12 hours cannot be carried forward to the subsequent cycle. Every two-year cycle resets to zero.
• CE Non-Compliance Penalties: TDI automatically assesses a fine of $50 for every hour not completed before midnight Central Time on the license expiration date, with no exceptions. For license terms that expired after June 1, 2018, the fine is capped at a maximum of $500 per license type; terms that expired before that date carry no cap. Paying the fine does not excuse the hours — the adjuster must both pay the fine and complete the deficient hours before the license can be renewed.
• Extensions: An adjuster who cannot finish on time may request an extension of time through Sircon, but the request must be submitted at least two weeks before the license expires.
• The 20-Year Exemption: An adjuster continuously licensed in Texas for at least 20 years without interruption may request a CE exemption; the request must also be made two weeks before expiration.
• Non-Resident CE: A non-resident adjuster generally satisfies Texas CE by complying with the home state's requirements. If the home state has no CE requirement — or if the adjuster holds a Texas Designated Home State (DHS) license — the adjuster must follow Texas rules.
• Reporting Lag: Because providers must transmit completions to TDI, complete CE hours at least 30 days before expiration to avoid a renewal delay.

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License Renewal Cycles & Tiered Late Renewal Penalties

Under Texas Insurance Code § 4003.001, adjuster licenses operate on a biennial renewal cycle.

                    LICENSE EXPIRATION & LATE CONSEQUENCES
                           (TIC 4003.001, 4003.007)
                                       |
         +-----------------------------+-----------------------------+
         v                             v                             v
   TIER 1: EXPIRED <= 90 DAYS    TIER 2: 91 DAYS - <1 YEAR    TIER 3: 1 YEAR OR MORE
   * RENEWAL is still allowed    * MAY NOT RENEW              * MAY NOT RENEW
   * Renewal fee + an extra fee  * Must obtain a NEW license  * Must obtain a NEW
     equal to 1/2 the renewal      WITHOUT re-examination       license WITH
     fee (TDI: $50 + $25)        * License fee + an extra       re-examination
   * All 24 CE hours verified      fee equal to 1/2 the       * Full original-license
                                   license fee ($50 + $25)      requirements apply
                                 * New IdentoGO prints

Expiration Mechanics

An individual adjuster license expires on the licensee's birth date every two years. If an adjuster was born in an even-numbered year, their license expires on their birthday in even-numbered years; if born in an odd-numbered year, it expires on their birthday in odd-numbered years. Corporate adjuster licenses expire on the anniversary of license issuance.

Tiered Late Renewal Structure (TIC § 4003.007)

Texas draws a hard statutory line at 90 days. Only inside that window is the transaction legally a renewal; after it, the adjuster is applying for a brand-new license. The exam tests this distinction directly.

1. Expired 90 Days or Less — TIC § 4003.007(a):
   • The licensee may renew by filing a renewal application and paying the required renewal fee plus an additional fee equal to one-half of the required renewal fee.
   • In practice: TDI's adjuster renewal fee is $50 and the late fee is $25, for a total of $75.
   • All 24 CE hours must be complete, and any CE fines paid, before TDI will process the renewal.
2. Expired More Than 90 Days but Less Than One Year — TIC § 4003.007(b):
   • The licensee may not renew the license. This is the single most commonly missed fact in this area.
   • The person may instead obtain a new license without taking the applicable examination by filing a new application and paying the license fee plus an additional fee equal to one-half of the license fee.
   • In practice: TDI directs the applicant to Sircon, selects "New Adjuster License," charges the $50 application fee, invoices a $25 late fee, and requires a copy of the IdentoGO fingerprint receipt.
3. Expired One Year or More — TIC § 4003.007(c):
   • The licensee may not renew. The person may obtain a new license only by submitting to re-examination (if an examination is required for original issuance) and complying with all other requirements and procedures for an original license.
   • In practical terms the candidate is back at square one: new application, new fingerprints, and either a new passing Pearson VUE score or a fresh § 4101.056 exemption.

Exam Trap: A distractor will offer "renew by paying the renewal fee plus a 100% penalty" for the 91-day-to-one-year window. There is no 100% penalty tier in § 4003.007. Every late fee in the statute is one-half of the underlying fee; what changes across the tiers is whether the transaction is a renewal, a new license without examination, or a new license with examination.

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Mandatory Contact Information Notification (TIC § 4001.252)

Licensed adjusters are constantly mobile, moving between catastrophe staging bases and corporate offices. Texas law imposes an affirmative reporting duty that is easy to overlook:

TIC § 4001.252(a): An individual license holder shall notify the department on a monthly basis of (1) a change of the license holder's mailing address; (2) a felony conviction of the license holder; or (3) an administrative action taken against the license holder by a financial or insurance regulator of this state, another state, or the United States.

• TDI's operational instruction is stricter and simpler than the statutory floor: "You must notify us immediately of changes to your contact information, legal name, or business name or address." Update contact information through TDI's name/address change process rather than waiting for a renewal cycle.
• Why it matters in practice: TDI mails the renewal invoice and all CE correspondence to the email and mailing address on file. An adjuster who moves without reporting does not stop the expiration clock — they simply stop receiving the warnings, and then discover the lapse after the 90-day renewal window has closed.
• Business entities (TIC § 4001.252(c)): A corporation or partnership licensed as an agent must notify TDI not later than the 30th day after a felony conviction of a licensed agent of the entity or an individual required to file biographical information, an event requiring notification under § 81.003, or the addition or removal of an officer, director, partner, member, or manager. The 30-day deadline is the entity rule — do not apply it to the individual adjuster's monthly reporting duty.
• Failure to report is an administrative violation that can support disciplinary action and fines under TIC Chapter 82 and §§ 4005.101–.102.

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Emergency & Catastrophe Adjuster Licenses (TIC § 4101.101)

Texas is subject to massive natural catastrophes—including hurricanes striking the Gulf Coast, widespread tornado outbreaks across North Texas, and severe hailstorms in the Dallas-Fort Worth metroplex. During a major disaster, the domestic supply of licensed Texas adjusters is quickly overwhelmed by tens of thousands of simultaneous property claims.

To ensure prompt claim investigation and disaster relief, the Legislature enacted the Emergency Adjuster Licensing statute, TIC § 4101.101.

+-----------------------------------------------------------------------+
|            EMERGENCY ADJUSTER LICENSE (TIC 4101.101)                  |
+-----------------------------------------------------------------------+
| 1. Event Trigger: A catastrophe or emergency arising out of a         |
|    disaster, act of God, riot, civil commotion, conflagration, or     |
|    other similar occurrence                                           |
| 2. Certifying Entity: A Chapter 4101 license holder, OR an insurer    |
|    that maintains an office in Texas and holds a Texas certificate    |
|    of authority                                                       |
| 3. Certification Deadline: NOT LATER THAN THE 5TH DAY after the date  |
|    the person BEGINS WORK as an adjuster                              |
| 4. Sponsor Liability: The certifying person or insurer is RESPONSIBLE |
|    for the loss and claims practices of the emergency licensee        |
| 5. Initial Term: Effective for a period NOT TO EXCEED 90 DAYS         |
| 6. Extension: The commissioner MAY extend the term for ONE additional |
|    90-day period (180 days maximum)                                   |
| 7. Fee: Not to exceed $20, remitted not later than the 30th day after |
|    TDI issues the license                                             |
| 8. Residency/Prior License: IRRELEVANT - the commissioner may issue   |
|    to a nonresident and to a person not otherwise licensed            |
| 9. Revocation: After notice and hearing, on Sec. 4101.201 grounds     |
+-----------------------------------------------------------------------+

The Five-Day Certification Deadline

The most frequently tested mechanic of § 4101.101 is who certifies and when. The commissioner "shall, on application, issue an emergency license" only if the application is certified to the commissioner not later than the fifth day after the date on which the person begins work as an adjuster. Texas therefore tolerates an emergency adjuster starting work before the license issues, provided the certification is filed inside that five-day window. The certifier must be either a Chapter 4101 license holder or an insurer that maintains an office in this state and holds a Texas certificate of authority.

Sponsor Responsibility

Under § 4101.101(b), the person or insurer that certifies the application is responsible for the loss and claims practices of the emergency license holder they certify. This is a real liability transfer, not a formality: a catastrophe vendor that certifies a poorly trained emergency adjuster answers to TDI for that adjuster's handling of Texas claims.

Duration, Extension, and Fee

• Initial Period: The emergency license "is effective for a period not to exceed 90 days."
• Extension: The commissioner — not the sponsor, and not automatically — may extend the term of the emergency license for an additional period of 90 days, for a maximum of 180 days.
• Fee: The commissioner establishes an emergency license fee not to exceed $20, which the license holder must remit to TDI not later than the 30th day after the date TDI issues the license.
• Eligibility: § 4101.101(f) lets the commissioner issue the license regardless of whether the applicant is a Texas resident or an otherwise licensed adjuster.
• Revocation: After notice and hearing, the commissioner may revoke an emergency license on the disciplinary grounds listed in § 4101.201.
• Post-Disaster Termination: When the term lapses, so does the license. The adjuster cannot continue handling Texas claims without a permanent license.

Distinguish the emergency license from the nonresident carve-out. TIC § 4101.002(b)(2) already allows an unlicensed nonresident to adjust "losses arising out of a catastrophe common to all those losses" with no Texas license at all. The § 4101.101 emergency license is the mechanism used when that narrow carve-out does not fit — for a Texas resident, or for an adjuster whose assignment is not confined to one common catastrophe.

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Non-Resident Licensing, Reciprocity & Designated Home State (DHS)

To facilitate the interstate mobility of claims professionals, Texas participates in national licensing reciprocity:

1. Reciprocity for Licensed Non-Residents

If an adjuster resides in a state that licenses adjusters (such as Florida, Georgia, or North Carolina) and passed an examination substantially equivalent to the Texas exam, TDI will issue a Texas Non-Resident Adjuster License on a reciprocal basis without requiring the applicant to sit for the Texas state exam or complete the 40-hour course.

2. The Designated Home State (DHS) Mechanism

Several states (such as Colorado, Illinois, Ohio, Pennsylvania, and Virginia) do not license independent claims adjusters. An adjuster living in a non-licensing state faces severe employment obstacles because other licensing states require proof of an active home state credential before granting reciprocal privileges.

To solve this dilemma, Texas allows non-residents living in non-licensing states to designate Texas as their Designated Home State (DHS):

• The non-resident candidate takes and passes the Texas All-Lines exam or completes the 40-hour course exemption.
• TDI issues a Texas DHS Adjuster License.
• The adjuster can then use their Texas DHS license to obtain non-resident reciprocal licenses across dozens of other states nationwide, making the Texas All-Lines DHS credential one of the most valuable assets in the catastrophe claims industry.

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Comprehensive Compliance Summary Table