What Carrier Agreements and State DOI Rules Actually Require From Your Insurance Website

Most insurance agents sign carrier agreements without fully reading the marketing provisions. These agreements typically contain specific restrictions on how you can represent the carrier on your website, in ads, and in client communications.

Common carrier restrictions that affect SEO content:

• Logo usage requirements — Many carriers require specific logo versions, minimum clear space, and prohibit modifications. Using an outdated logo or placing it on certain background colors can violate your agreement.
• Comparative claims — Statements like "best rates in the market" or "better coverage than [competitor]" typically violate co-op advertising rules, even if technically accurate.
• Guarantee language — Phrases like "designed to approval" or "coverage designed to" are prohibited by most carrier agreements and many state regulations.
• Product name accuracy — Using informal product names instead of official registered names can create compliance issues.

Before publishing any page mentioning a carrier by name, review your agreement's advertising provisions. Many carriers require pre-approval for any marketing materials that include their brand — this includes website pages, not just traditional ads.

Co-op reimbursement requirements: If you're seeking co-op advertising reimbursement for digital marketing, carriers typically require specific disclaimer language, approved messaging, and sometimes pre-approval of the exact content. SEO content rarely qualifies for co-op reimbursement because it doesn't meet the time-bound campaign requirements most programs specify.

Note: This is educational content about common carrier agreement provisions, not legal advice. Review your specific carrier agreements and consult with your compliance officer or attorney for binding guidance.

Testimonials on insurance websites operate under three overlapping regulatory frameworks: FTC endorsement guidelines, state Department of Insurance advertising regulations, and carrier-specific restrictions. Understanding where these overlap — and where they differ — determines what you can actually publish.

FTC Endorsement Guidelines (federal baseline):

• Testimonials must reflect honest opinions of real clients
• Material connections must be disclosed (e.g., if you provided incentives for reviews)
• Atypical results require clear disclosure that results aren't designed to
• You cannot edit testimonials to change their meaning

State-specific testimonial restrictions:

California Insurance Code §790.03 prohibits testimonials that misrepresent policy benefits. Texas Administrative Code Title 28 requires that testimonials not imply designed to coverage outcomes. New York's Regulation 34 addresses unfair claims settlement but affects how you can characterize claims experiences in testimonials.

What you can safely do:

• Request reviews that focus on service quality, responsiveness, and communication
• Publish testimonials about your agency's helpfulness during the quoting process
• Share reviews that describe general satisfaction without specific coverage outcome claims

What creates compliance risk:

• Testimonials stating "they got my claim paid in 3 days" (implies outcome guarantee)
• Reviews mentioning specific premium savings without context
• Incentivizing reviews with gift cards or discounts (FTC violation)
• Selectively publishing only 5-star reviews without disclosure

State regulations change frequently. Verify current rules with your state DOI before implementing any testimonial solicitation program.

Different insurance product lines have distinct disclosure requirements. Using a generic disclaimer across all pages creates gaps that regulators and carriers can identify during audits.

Health insurance website disclaimers:

Pages discussing health coverage typically require ACA marketplace disclosures, Medicare-specific disclaimers if applicable, and state-specific health insurance notices. Example baseline language: "Coverage options and premiums vary by location, age, and other factors. This information is not a complete description of benefits. Contact the plan for more information."

Life insurance website disclaimers:

Life insurance pages should clarify that quotes are estimates, coverage requires underwriting approval, and policy terms vary by carrier. Example: "Life insurance coverage requires completion of an application and is subject to underwriting approval. Premium quotes are estimates and final rates may differ based on health history and other factors."

Property & casualty disclaimers:

P&C pages benefit from disclaimers noting that coverage availability varies by location, deductibles affect premiums, and claims are subject to policy terms. Example: "Insurance coverage is subject to policy terms, conditions, and exclusions. Not all coverages or discounts are available in all states or situations."

Placement and formatting:

• Disclaimers should appear on the same page as the relevant content, not just in site footers
• Font size should be readable — typically no smaller than body text
• Color contrast must be sufficient (avoid light gray on white)
• Mobile visibility matters — disclaimers must be accessible on all devices

These templates are starting points. Consult your carrier compliance departments and legal counsel for approved language specific to your products and states.

Google Business Profile reviews and third-party review platforms create compliance considerations that differ from testimonials you directly publish on your website. You have less control over what clients write, but you still have obligations.

What you control:

• Review solicitation language — How you ask for reviews matters. Asking "tell others about your experience with our agency" is safer than "share how we saved you money on your policy."
• Response content — Your replies to reviews become your published content. Avoid confirming specific coverage details, premium amounts, or claim outcomes in public responses.
• Review gating — Directing happy clients to public reviews while routing unhappy clients elsewhere violates FTC guidelines and some platform terms of service.

What you cannot control (but must monitor):

Clients may write reviews mentioning specific carriers, claim amounts, or premium savings. While you cannot edit their reviews, you can flag reviews that violate platform guidelines (if they contain prohibited content) and respond appropriately without confirming regulated information.

Review response best practices:

When responding to reviews that mention specific coverage outcomes or savings, acknowledge the client's satisfaction without confirming the specifics: "Thank you for your kind words, Sarah. We're glad we could help you find the right coverage for your family."

Avoid: "Thanks for sharing how we saved you $400/month on your health insurance!" — This confirms a specific outcome that may not be typical and could be seen as an implied guarantee.

Insurance regulations and carrier agreements change frequently. A quarterly audit process helps catch issues before they become complaints or contract violations.

Carrier compliance review:

• Verify all carrier logos match current approved versions
• Confirm product names match official registered names
• Check that no pages contain comparative claims against competitors
• Review any pages using "guarantee" or "assured" language
• Verify co-op advertising compliance for any reimbursement-eligible content

Testimonial and review audit:

• Review all testimonials for outcome-specific language that implies guarantees
• Verify disclosure language is present for any incentivized reviews
• Check that testimonial dates are accurate (don't present old testimonials as recent)
• Confirm review solicitation emails/texts don't contain leading language

Disclaimer verification:

• Confirm each product line page has appropriate disclaimer language
• Verify disclaimers are visible on mobile devices
• Check that font size and contrast meet readability standards
• Ensure footer disclaimers haven't been removed during site updates

State-specific compliance:

• If operating in multiple states, verify content complies with the most restrictive applicable regulation
• Check for any new DOI guidance or advertising bulletins in your licensed states
• Review any recent enforcement actions in your states to identify emerging compliance focus areas

Document each audit with dates, findings, and remediation actions. This documentation demonstrates good faith compliance efforts if questions arise.

Compliance violations in insurance marketing aren't theoretical risks. Agencies experience real consequences ranging from carrier termination to DOI fines and license actions.

Carrier agreement violations:

Using unapproved marketing materials or misrepresenting carrier products can result in termination of your appointment. Many agencies report losing carrier appointments after compliance audits identified unauthorized comparative claims or logo misuse. Reinstatement often requires completing additional compliance training and waiting periods.

State DOI advertising complaints:

Consumer complaints about misleading website content typically trigger DOI review. If investigators find violations of state advertising regulations, consequences can include fines, required corrective advertising, and in serious cases, license suspension. Many states publish enforcement actions publicly, creating lasting reputation damage.

FTC testimonial violations:

The FTC has increased enforcement of endorsement guidelines across industries. While insurance-specific FTC actions are less common than carrier or DOI enforcement, violations can result in consent orders requiring specific compliance measures and ongoing monitoring.

Common triggers for compliance review:

• Competitor complaints to DOI about your advertising
• Client complaints after coverage didn't meet expectations set by website content
• Carrier compliance audits (often triggered by co-op reimbursement requests)
• Random DOI advertising audits in states with active enforcement

The cost of compliance — reviewing content, updating disclaimers, training staff — is significantly lower than the cost of violations. Most agencies that experience enforcement actions report they wished they had invested in proactive compliance review.

For specific guidance on your compliance obligations, consult with an attorney familiar with insurance advertising regulations in your licensed states.