2026-09-10 · Kentucky · Regulation

What happened. On 11 March 2026 the Kentucky Department of Insurance issued Bulletin 2026-01 to all property and casualty insurers authorised to do business in the Commonwealth, setting out the Department's position on cancellations, nonrenewals and claim denials based on satellite and aerial imagery.¹

It was signed by Commissioner Sharon P. Clark. The Department notes that at least eleven other states have issued comparable guidance — Alabama, Connecticut, Delaware, Maine, Maryland, Massachusetts, Michigan, New Hampshire, Pennsylvania, Rhode Island and West Virginia.

The rule on satellite imagery

The Bulletin grounds itself in KRS 304.12-230, under which it is an unfair claim settlement practice for an insurer to misrepresent pertinent facts relating to the claim or coverage, or to refuse to pay a claim without conducting a reasonable investigation based upon all available information.

Its conclusion is direct:

“Satellite images of insured property — by themselves — fail to capture ‘all available information’ relevant to a claim and, therefore, cannot reasonably justify the denial of a property damage claim, standing alone. Satellite images generally cannot provide a clear, up-to-date representation of insured property. Accordingly, satellite images, alone, are insufficient to justify a cancellation or nonrenewal pursuant to KRS 304.20-320 without further investigation. Thus, to remain compliant with the above-referenced statutory requirements, an insurer may not rely on satellite imagery as the sole basis for cancellation, nonrenewal, or claim denial.”

The Bulletin closes a second door as well: satellite imagery “may not be used as a basis for cancellation or nonrenewal solely in conjunction with any reason identified in KRS 304.20-340 that also may not be used as a sole basis.” Insurers may use satellite data as a tool to identify degradation or damage, but “must conduct further investigation to validate any suspected issues.”

Aerial images: allowed, on three conditions

Drone and aircraft images are treated differently. They may generally support a cancellation, nonrenewal or claim denial if:

1. “the images are sufficiently clear to allow an individual to visualize the specific property conditions that are noncompliant with the insurer's underwriting guidelines”;
2. “the images are accompanied by a written summary which clearly identifies the specific property conditions that are noncompliant with the insurer's underwriting guidelines”; and
3. “the images contain a date stamp showing they were taken within the last 12 months.”

Images that are “low-resolution, out-of-focus, blurry, or dated cannot be used to justify a cancellation, nonrenewal, or claim denial.”

The roof-streaking sentence

“Furthermore, both satellite and aerial images of a roof displaying streaking or discoloration are not sufficient to independently support cancellation, nonrenewal, or claim denial based on roof degradation.”

1. Kentucky Department of Insurance Bulletin 2026-01, 11 March 2026 — Use of Satellite/Aerial Imagery as Basis for Cancellations, Nonrenewals, and Claim Denials ↩
2. Kentucky Department of Insurance — bulletins index ↩
3. HB 568 (2026), 2026 Ky. Acts ch. 141 — two-year moratorium on new public adjuster licences ↩