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California's Rules for Rating on Verified Miles

Quick answerNot for rating. California lets insurers offer optional programs that rate on verified actual mileage, but a device used for them may collect only what is needed to determine miles driven and may not collect or store the car's location, except for emergency road, theft, map or travel services. Joining is voluntary, every verification method a company offers must be open to everyone, and any discount must reflect demonstrated savings.

Plug-in devices and phone apps make people wary, and the first question is usually the right one: what does it record? For the mileage factor, California answers in its rating regulation, 10 CCR 2632.5(c)(2)(F).

Two ways to rate mileage

The standard approach rates each car on an estimate of the miles it will be driven in the next twelve months. The regulation also lets insurers offer an optional verified actual mileage program, in which the rating uses miles that have been checked. Per-mile pricing is permitted inside such a program.

How miles may be verified

The regulation lists the methods: odometer readings taken by the insurer's staff or a vendor, records from a repair shop, smog-check or other government records, odometer readings reported by the insured, technological devices, and other methods the Insurance Commissioner approves. An insurer must make every verification method it offers available to all insureds equally, and may not use a method it does not offer uniformly to the public.

That matters if you dislike devices. If a company offers odometer readings as well as a device, you are entitled to the readings.

What a device may record

An insurer may use a device only to collect the information needed to determine actual miles driven. It may not use it to collect or store information about the location of the vehicle. The exception is narrow: emergency road, theft, map or travel services provided by a motor club or the insurer.

What the law allowsOptional programs rating on verified miles, using methods offered equally to all, with devices limited to mileage data and barred from storing location except for listed services.
What you can changeWhether you join, and which of the offered verification methods you use.
What you can'tA company's choice to require verified mileage on every car of a policy once you choose it for one.

Voluntary, with one wrinkle

An insurer that offers estimated mileage may not require any policyholder to join a verified program. The wrinkle is that an insurer offering verified mileage for one vehicle may require it for all the vehicles on the same policy, so ask before you enrol one car.

The money rules are written to keep programs honest. Any discount must rest on demonstrated cost savings or actuarial accuracy from using actual rather than estimated miles, and if a discount is offered, every participant qualifies whichever verification method they use. Adjustments based on actual miles, backwards or forwards, are allowed only if you were told before the policy's effective date. And an insurer may not require you to produce information from a prior insurer to confirm your mileage.

What to ask before you sign up

The rule described here governs devices used to verify miles. If a company's program measures anything beyond mileage, ask it to explain in writing what is collected and how it is used. To compare a verified-mileage option with a standard estimate, ask for both quotes.

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More of what callers ask

Can my insurer make me use a mileage device?

Not if it offers estimated mileage; verified programs are voluntary. If you choose verified mileage for one car, though, the insurer may require it for every car on that policy.

Does a mileage device record where I go?

California's regulation bars insurers from using a device to collect or store the vehicle's location, except for emergency road, theft, map or travel services.

Can I verify my miles without a device?

If the company offers other methods, such as odometer readings or smog-check records, it must make them available to every insured equally.

Will a new insurer ask my old insurer for my mileage?

It may not require you to provide information from a prior insurer to confirm mileage.