New Jersey Travel Insurance Act: What You Need to Know Before April 18

The New Jersey Department of Banking and Insurance has issued Bulletin 26-02, offering guidance on the Travel Insurance Act (N.J.S.A. 17:46E-1 to -9), which becomes effective April 18, 2026.

While additional regulations are expected in the future, the message from the state is clear: compliance is required now, not later.

For organizations involved in travel insurance, including producers, travel administrators, travel retailers, and insurers, this bulletin introduces new expectations that will directly impact licensing, oversight, and operational responsibility.

Access the full bulletin, Appendix A, and the Travel Retailer Register here: New Jersey Bulletin #26-02

Licensing Requirements Are Expanding

Under the Act, a producer license is required for any individual or business entity that sells, solicits, or negotiates travel insurance, or acts as a travel administrator handling premiums, claims, or related activity.

This includes:

• Traditional insurance producers
• Travel administrators
• Any entity involved in underwriting, collecting, or adjusting travel insurance related transactions

In most cases, this means holding:

• A Property & Casualty license, or
• A Limited Lines Travel Insurance license

This is a key shift. Organizations that previously operated in a more limited or indirect capacity may now fall within licensing requirements.

A New Layer of Responsibility for Producers

One of the most important takeaways from the bulletin is the level of responsibility placed on Travel Insurance Producers.

Producers are now required to:

• Designate a responsible producer accountable for compliance
• Maintain a state-prescribed register of travel retailers (Appendix A)
• Ensure all applicable licensing fees are paid
• Confirm compliance with federal background requirements (18 U.S.C. §1033)

More importantly, producers are responsible for the conduct of their travel retailers.

This is not a passive relationship. It creates direct accountability for how travel insurance is offered and sold under their license.

Travel Retailers: Clear Limits and New Expectations

The Act also defines what travel retailers can, and cannot, do.

Travel retailers:

• Do not need to be licensed if operating under a registered Travel Insurance Producer
• Must be included in the official register
• Must complete required training before offering travel insurance

However, there are clear restrictions.

Unlicensed travel retailers cannot:

• Interpret policy terms or benefits
• Provide advice on coverage adequacy
• Represent themselves as licensed insurance professionals

They are limited to providing general information only, such as:

• Coverage descriptions
• Pricing details

This distinction is critical and will require organizations to clearly define roles and responsibilities across their distribution channels.

Training and Consumer Disclosure Requirements

The bulletin introduces more structured expectations around training and transparency.

Travel Insurance Producers must ensure that retailer employees receive training that includes:

• Types of coverage offered
• Ethical sales practices
• Required consumer disclosures

In addition, consumers must be provided with clear, approved materials that include:

• Insurer and producer contact information
• Disclosure that purchase is not required
• Clarification that unlicensed retailers cannot provide advice

After purchase, customers must also receive:

• Coverage details
• Claims instructions
• Cancellation and review information

These requirements reinforce a consistent theme: clarity and consumer protection.

Insurer Oversight and Filing Requirements

Insurers also have defined responsibilities under the Act.

They must:

• Approve all consumer-facing materials
• Oversee travel administrators acting on their behalf
• Ensure proper recordkeeping and availability for review

Additionally, travel insurance must now be filed under:

• Personal Inland Marine, or
• Accident & Health, depending on coverage type

All filings must go through SERFF (System for Electronic Rates & Forms Filing) and include certification that forms comply with applicable laws and regulations.

What This Means Operationally

Even without final regulations, this bulletin signals a shift toward more structured oversight and accountability across all parties involved in travel insurance.

Key operational impacts include:

• Increased licensing validation requirements
• Formal tracking of travel retailer relationships
• Expanded compliance accountability for producers
• More detailed training and documentation processes

Organizations relying on manual processes or fragmented systems may find it difficult to keep up with these requirements, especially as enforcement expectations increase.

Why This Matters Now

The effective date is April 18, 2026, but compliance is not something that can be implemented overnight.

Between:

• Licensing verification
• Retailer registration tracking
• Training requirements
• Documentation and disclosure updates

There are multiple moving parts that need to be aligned in advance.

Organizations that take a proactive approach now will be better positioned to avoid delays, reduce risk, and maintain operational continuity.

Final Thoughts

New Jersey’s Travel Insurance Act introduces a more defined framework for how travel insurance is sold, managed, and regulated.

While additional guidance may still be coming, the expectations outlined in Bulletin 26-02 are already in effect.

For producers, retailers, administrators, and insurers, this is not just a regulatory update, it’s a shift in how responsibility is assigned and managed across the lifecycle of travel insurance.

Ensuring your organization is aligned now will make all the difference as enforcement and oversight continue to evolve.

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