New Jersey's new Travel Insurance Act takes effect April 18, reshaping how producers, retailers, and insurers sell travel coverage statewide.
Acting Commissioner Susan Ochs signed Bulletin No. 26-02 on April 1, 2026, offering the industry official guidance on the Travel Insurance Act, codified at N.J.S.A. 17:46E-1 to -9. The law applies to any travel insurance policy covering a New Jersey resident that is sold, solicited, negotiated, or offered in the state, as well as policies and certificates delivered or issued for delivery there.
The new framework touches virtually every corner of the travel insurance distribution chain. If you sell it, administer it, underwrite it, or offer it at the point of sale, the Act has something to say to you.
Starting with licensing, the Act requires anyone who sells, solicits, or negotiates travel insurance to hold a producer license with authority in property or casualty, or limited lines travel insurance. Travel administrators – those who underwrite, collect premiums, or adjust claims – must be licensed as producers with authority in property and casualty, or operate as managing general agents. The Department of Banking and Insurance has signaled it will promulgate further regulations, but compliance is expected from day one regardless.
One notable addition is the requirement for every travel insurance producer to appoint a designated responsible producer. This individual is personally accountable for making sure the producer and all of its registered travel retailers comply with all applicable travel insurance laws and regulations. Key officers who direct or control insurance operations must also meet fingerprinting requirements in the resident state of the limited lines travel insurance producer.
Producers now need to maintain a formal register of every travel retailer that offers coverage on their behalf, using a form prescribed by the Commissioner and attached to the bulletin as Appendix A. That register must include a certification confirming the retailers comply with 18 U.S.C. § 1033, the federal provision that keeps individuals convicted of felonies involving dishonesty or breach of trust out of the insurance business unless they obtain written consent from the Commissioner. The register must be submitted to the Department upon reasonable request.
Training standards have also been tightened. Every travel retailer employee involved in offering and disseminating travel insurance must receive instruction covering the types of insurance offered, ethical sales practices, and required disclosures to prospective customers.
Travel retailers themselves – the agencies and businesses that make, arrange, or offer planned travel – can continue to offer travel insurance to their customers, but only on behalf of and under the direction of a licensed travel insurance producer. An unlicensed retailer cannot evaluate or interpret technical terms, benefits, and conditions of travel insurance coverage, advise customers on existing coverage, or hold itself out as a licensed insurer, licensed producer, or insurance expert.
Consumer-facing obligations round out the picture. Retailers must provide prospective purchasers with insurer-approved written materials that include the identity and contact information of the insurer and the limited lines travel insurance producer, make clear that buying travel insurance is not required in order to purchase any other product or service from the travel retailer, and explain the limits of what an unlicensed retailer can discuss. After a purchase, policyholders must receive a description of the material terms or the actual material terms of the insurance coverage, information on how to file a claim, how to review or cancel the travel insurance policy, and the identity and contact information of both the insurer and the producer.
The Act also names specific conduct that crosses the line. Selling a travel insurance policy that could never result in payment of any claims, or marketing blanket travel insurance coverage as free, are both identified as unfair trade practices under N.J.S.A. 17:46E-7.
Insurers carry their own set of responsibilities under the new law. They must approve all written materials distributed by travel retailers, answer for the acts of any travel administrator who administers travel insurance they underwrite, and ensure those administrators maintain all books and records relevant to the insurer, available to the Commissioner upon request.
On the filing side, travel insurance must be classified under either a personal inland marine line or an accident and health line. Rates, rules, and forms go through SERFF. Policies providing coverage for only accident and sickness must be filed as accident and health; all other travel policies fall under personal inland marine. The bulletin spells out the specific filing codes – TOI 09.0 with Sub-TOI 09.0009 for inland marine, and TOI H19G for group health travel. Each submission needs a certification from a responsible officer of the insurer attesting that the forms comply with all applicable laws, rules, bulletins, and published guidelines.
Products already approved as of the effective date stay in force, and travel insurance bundled as a rider or part of another policy falls outside the Act entirely, continuing under existing law for that product type.
Premium tax rules round out the Act. Insurers owe premium tax on travel insurance premiums paid by individual primary policyholders who are New Jersey residents, primary certificate-holders who are New Jersey residents electing coverage under a group travel insurance policy, and blanket travel insurance policyholders that are residents in or have their principal place of business – or the principal place of business of an affiliate or subsidiary that has purchased blanket travel insurance – in the state, subject to any apportionment rules that apply across multiple taxing jurisdictions.
The April 18 deadline leaves little room for delay. With regulations still to come but compliance expected immediately, producers, administrators, retailers, and insurers doing business in New Jersey would be wise to start reviewing their operations now.
