Storm and Flood
Insurance matching for roofs and siding: when undamaged parts must be replaced
Checked against official sources
When hail or wind damages one slope of a roof or one wall of siding, the new material often does not match what is left: the shingle line is discontinued or the old color has faded. Whether your insurer pays only for the damaged section or for enough of the house to look uniform depends on your policy and your state. In Kentucky, for example, the Department of Insurance said in 2023 that if shingles on one slope are damaged by a covered loss and matching shingles are unavailable, the insurer must replace the entire roof. This article explains where matching rules come from, how some states apply them, and what to document.
What the matching problem is
A partial repair can leave a patchwork of new and weathered material. Disputes usually turn on three points:
- whether the replaced items reasonably match the undamaged ones;
- how far the repair must extend: one slope or the whole roof, one wall or every wall;
- whether an endorsement in your policy limits matching.
Where matching rules come from
Several state rules use wording close to the National Association of Insurance Commissioners (NAIC) Unfair Property/Casualty Claims Settlement Practices Model Regulation, adopted in its current form in 1990. Its section 9(A)(2) says that when replaced items do not match in quality, color or size, the insurer shall replace all items in the area to achieve a reasonably uniform appearance, for interior and exterior losses, with no cost to the insured beyond the deductible. Each state decides whether and how to adopt it.
Matching rules in some states
| State | What the rule says |
|---|---|
| Kentucky (806 KAR 12:095, Section 9) | Replace all items in the area to conform to a reasonably uniform appearance; the 2023 advisory opinion reads area as, for example, an entire roof, with no line of sight limit |
| Florida (Fla. Stat. 626.9744) | Unless the policy provides otherwise, reasonable repairs or replacement in adjoining areas; the insurer may consider cost, achievable uniformity and the remaining useful life of undamaged parts |
| California (10 CCR 2695.9(a)(2)) | Replace all items in the damaged area so as to conform to a reasonably uniform appearance |
| Ohio (Ohio Adm. Code 3901-1-54(I)(1)(b)) | Replace as much of the item as needed for a reasonably comparable appearance |
Kentucky's advisory opinion adds that the same shingles, if still in production, satisfy the rule even when the old roof has faded with age, and that insurers had to amend forms placing a sublimit on matching by September 1, 2024. Other states have different rules or none, and there the policy wording usually decides.
What your policy says
In the standard ISO homeowners form (HO 00 03, 2011 edition), dwelling damage is settled at the replacement cost of that part of the building damaged, with material of like kind and quality and for like use, when the home is insured to at least 80% of its replacement cost. Until the repair is complete, the form pays no more than actual cash value, unless the cost is both less than $2,500 and less than 5% of the dwelling limit. If you accept actual cash value first, you can still claim on a replacement cost basis if you notify the insurer within 180 days after the date of loss of your intent to repair or replace.
Some policies include an endorsement that limits matching, such as a sublimit for matching undamaged areas; check your declarations page and endorsements.
How to document a matching issue
- Photograph each damaged area close up and from a distance, showing the boundary with undamaged material.
- Record the product: shingle brand and line, siding profile and color, and any label or leftover material.
- Ask your contractor in writing whether matching material is still made, and keep any supplier statement.
- Note where a repair would stop: the slope, the wall, the room.
- Compare the adjuster's estimate with your contractor's, area by area.
Asking the insurer to explain
The Colorado Division of Insurance advises homeowners to ask the adjuster for an itemized explanation of any settlement offer, to ask for the specific policy language if they disagree, and to request a written denial letter giving the reason and the policy language relied on. The NAIC model also says a denial based on a policy provision must reference that provision and be given in writing. If you still disagree, your state insurance department, listed in the NAIC directory, offers consumer help and takes complaints.
Putting it together
The Hurricane and Wind Damage Claim Kit turns these steps into ready-to-use files, with nothing pre-filled that should come from your records, your policy or your insurer:
- US_Hurricane_Wind_User_Guide.docx: step-by-step guide with key terms, rules that may apply and sources.
- US_Hurricane_Wind_Damage_Areas_Log_TRACKER.xlsx: area-by-area damage record: observations, photos, temporary repairs.
- US_Hurricane_Wind_Contents_Inventory_TRACKER.xlsx: room-by-room contents inventory for belongings damaged inside.
- US_Hurricane_Wind_ALE_TRACKER.xlsx: additional living expenses tracker, if you cannot stay home during repairs.
- US_Hurricane_Wind_Claim_Diary_TRACKER.xlsx: claim diary with key dates, alerts and a contact log.
- US_Hurricane_Wind_Claim_Letters_TEMPLATE.docx: editable letters to request documents or information and confirm calls in writing.
Record each slope and wall in the Damage Areas Log with photos and product details, enter the 180-day date in the Claim Diary, and use the letters to request the estimate and a written explanation.
Quick checklist
- Loss settlement section and every endorsement read, including any matching limit.
- Damaged and undamaged areas photographed, boundary visible.
- Shingle or siding product identified; availability confirmed in writing.
- Estimates compared area by area.
- Written explanation requested for any refusal to match.
- 180-day replacement cost notice date in the diary.
General information, not legal or insurance advice. Your policy decides what is covered.
Sources
- NAIC Unfair Property/Casualty Claims Settlement Practices Model Regulation #902
- Kentucky Administrative Regulations, 806 KAR 12:095 Unfair claims settlement practices for property and casualty insurance
- Kentucky Department of Insurance, Advisory Opinion 2023-08 regarding matching
- Florida Statutes section 626.9744
- California Department of Insurance, 2026 Guide for Adjusting Property Claims in California After a Major Disaster
- Ohio Administrative Code rule 3901-1-54
- ISO HO 00 03 05 11 Homeowners 3 Special Form (Maine Bureau of Insurance)
- Colorado Division of Insurance, Consumer advisory: tips after severe hailstorm (May 22, 2024)
- NAIC directory of state insurance departments
The kit for this situation
Hurricane and Wind Damage Claim Kit
Damage areas log, inventory, living expenses, diary and letters after a hurricane or windstorm.
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