An Oregon order froze master-policy cancellations — until this month
An Oregon order froze master-policy cancellations — until this month
2026-09-15 · Oregon · Regulation
Oregon's insurance regulator ordered every admitted property and casualty insurer in the state to stop cancelling and nonrenewing policies in wildfire-affected areas — and the order is not limited to homeowner policies. On its own terms it reaches association master policies, and it expires around September 29, 2026.1
Scope
The order, signed by Insurance Commissioner TK Keen on July 31, 2026 under ORS 731.870, sets its own reach:
“This Order is directed to all admitted insurers that provide any type of property and casualty insurance coverage in Oregon. The Order applies to all insurance policies issued, delivered, or covering a risk in the affected geographic areas as specified by bulletins issued by the Director… specified by ZIP code or other appropriate means of delineation.”2
“Any type of property and casualty insurance coverage” on “all insurance policies…covering a risk in the affected geographic areas” is commercial-lines language. It is not confined to personal homeowner policies, and the word “homeowner” appears nowhere as a limiter. An association master property policy covering a building in an affected ZIP code is a policy covering a risk in an affected geographic area.
What insurers were ordered to do
“a. Except as provided in subsection (e), insurers must suspend all cancellations and nonrenewals until this Order is no longer in effect. b. For insurance policies not yet cancelled or nonrenewed as of the date of this Order, but for which a notice of cancellation or nonrenewal has been delivered, insurers must withdraw the issued notice and provide insureds with a notice that cancellation and nonrenewal is suspended during the time this Order remains in effect.”2
Paragraph (b) is the operative one for a board holding a nonrenewal letter dated before July 31. That notice had to be withdrawn, and the insurer had to say so in writing.
Subsection (c) suspends the 60-day underwriting cancellation window for the duration of the order, and requires 30 days' notice after it lifts for cancellations under ORS 742.562(2), 746.687(6) and 742.710(1)(a). Subsection (e) bars cancelling or nonrenewing “solely because of a claim” arising from the wildfire, absent fraud or intentional misrepresentation.
Paragraph 12 requires an immediate grace period for premium payment across all covered policies, “ending no earlier than the first date on which this Order is no longer in effect.” Paragraph 14 is the limit: nothing in the order “shall be construed to relieve insureds of the obligation to pay premiums that are due.”
The clock
ORS 731.870 caps an emergency order at 30 days, extendable at the Director's discretion. The original ran July 31 to August 30, 2026. It was extended on August 26 for a further 30 days, carrying it to approximately September 29, 2026.3
That means a board reading this in the second half of September has days, not weeks. When the order lapses, the suspension lapses with it, and a withdrawn nonrenewal notice can be reissued.
Finding out whether a property is covered
The affected areas are set by bulletin, not by the order. Bulletin DFR 2026-6, revised August 31, 2026, lists them by ZIP code in dated tranches — an initial list covering Baker, Crook, Deschutes, Grant, Harney, Jefferson, Malheur, Umatilla, Union, Wasco and Wheeler counties, then additions on August 3, 5, 7, 10 and 11 that expanded it substantially into Clackamas, Douglas, Hood River, Jackson, Josephine, Klamath, Lane, Linn, Marion, Morrow, Multnomah, Sherman, Wallowa, Gilliam and Lake.4
The August 31 revision runs to 76 distinct ZIP codes. Widely circulated figures of “50 ZIP codes, 24 counties” describe the earlier version of the bulletin and understate the current reach. Check the ZIP code, not the county name.
The predicate
The order rests on Governor Kotek's Executive Order 26-10 declaring a statewide state of emergency under ORS 401.165 for critical fire danger in mid-June 2026, followed by executive orders 26-13 through 26-22 invoking the Emergency Conflagration Act between July 11 and July 26.
One caution on dates: the order's own findings give EO 26-10 as June 16, 2026 while its footnote gives June 15. The document is internally inconsistent by one day, so neither date should be stated with confidence.
A board's options before the order lapses
Four things, in order.
First, check the property's ZIP code against the current bulletin, not against a news summary.
Second, if the association received a cancellation or nonrenewal notice on the master policy and the property is in a listed ZIP, confirm in writing that the insurer withdrew it as paragraph 13(b) required. A withdrawal that never arrived is a compliance question for the Division, and the time to raise it is while the order is live.
Third, if the policy is in a grace period under paragraph 12, understand that the premium is still owed. Paragraph 14 says so expressly, and an association treating a grace period as forgiveness is heading into a lapse.
Fourth, use the separate statutory entitlement. House Bill 2563 from the 2025 session, operative September 1, 2026, requires insurers to give “a clear and reasonable explanation of the reasons for any increase in the premium amount for a qualified policy upon renewal,” including up to four significant contributing factors. On the next master-policy renewal with an increase, demand that explanation in writing. It is a documented reason set the board can take to a broker and to owners.
Why there is no fallback
An Oregon condominium association that loses its master policy has, in practice, no state backstop. The Oregon FAIR Plan's dwelling programme covers one-to-four family dwellings only, to a maximum of $600,000 across all coverage parts, on an actual cash value basis. Its commercial programme is capped at $1,000,000 for all coverage parts combined, on the ISO Standard Property Policy, with windstorm, hail, smoke, vandalism and other perils optional rather than included.5
Neither insures a condominium building to anything close to replacement cost, and neither can satisfy the 100 percent replacement-cost-value requirement that conventional lenders impose. Our Oregon insurance requirements page covers what the association's own documents and statute require it to carry.
What to watch next
Whether the Director extends again. ORS 731.870 permits it, the 2026 fire season was severe enough to produce ten conflagration orders in sixteen days, and the Division has used the emergency order rather than rulemaking as its instrument throughout — its published rulemaking calendar for 2026 contains nothing on homeowners insurance, wildfire or nonrenewals at all.
Related Oregon HOA Topics
- Oregon orders pause on insurance cancellations for wildfire-affected policyholders, Division of Financial Regulation ↩
- Wildfire Emergency Order, Oregon Department of Consumer and Business Services, July 31, 2026 ↩
- Extension of the Wildfire Emergency Order, August 26, 2026 ↩
- Bulletin DFR 2026-6, Affected Areas Subject to the Wildfire Emergency Order, revised August 31, 2026 ↩
- Commercial insurance coverages, Oregon FAIR Plan Association ↩
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