Comparable vehicles: what insurers may and may not use

Almost every total-loss offer starts the same way. The insurer's software finds vehicles it considers comparable to yours, averages what they cost, adjusts for differences, and calls the result actual cash value. If the comparables are wrong, everything downstream is wrong too — and unlike a condition adjustment, which is a judgment call, a comparable either meets the state's criteria or it does not.

That is what makes this the most productive thing to check first.

What "comparable" means, and who decides

Most states that regulate total-loss settlements say something about which vehicles may be averaged. What they say varies more than you would expect: some set a radius in miles, some define a market area and leave the distance open, and a good many say nothing at all.

State	What the rule says	Citation
Alabama	A comparable automobile must be by the same manufacturer, of the same model year, with similar body style and condition, similar options and similar mileage. Alabama attaches no numeric limits — no minimum count, no radius, no recency window and no mileage tolerance — but does require a replacement vehicle to be available for inspection within a reasonable distance of the insured's residence.	Ala. Admin. Code r. 482-1-125-.08(a), (b) checked Sep 5, 2026
Alaska	Comparables must be sourced from the LOCAL MARKET AREA using dealer quotations, computerized databases, or published industry sources. Where none is available locally the search area may be expanded to surrounding areas IN 25-MILE INCREMENTS. Where dealer quotations are used, two or more cost quotations must be obtained from two or more licensed dealers.	3 AAC 26.080(a)(1)(B) checked Sep 5, 2026
Arizona	None. R20-6-801 uses the term 'comparable automobile' throughout the total-loss subsection but never defines it, and sets no distance or market-area limit, no recency window, no minimum number of comparables and no mileage tolerance. What the rule does constrain is deductions: every deduction from the cost, salvage included, must be measurable, discernible, itemized and specified as to dollar amount, and appropriate in amount.	Ariz. Admin. Code R20-6-801(H)(1)(c) checked Sep 5, 2026
Arkansas	The cost of a comparable automobile in the LOCAL MARKET AREA where one is available; where none is available locally, one of two or more quotations obtained by the insurer from two or more qualified dealers or appraisal services located within the local market area. Arkansas sets no distance in miles, no recency window and no mileage tolerance, and does not define 'local market area'.	Ark. Ins. Rule 43 § 10(a)(2)(A), (B) checked Sep 5, 2026
California	'Comparable automobile' = like kind and quality, same manufacturer, same or newer model year (newer only if insufficient same-year comps), same model type, similar body type, options and mileage similar to the insured vehicle. Each comp must have been available for retail purchase by the general public in the local market area within 90 calendar days of the final settlement offer, and must be identified by VIN, dealer stock/order number, or license plate plus the seller's phone number or street address. Any adjustments must be discernible, measurable, itemized, specified, appropriate in dollar amount and documented in the claim file; unsupported deductions may not be used; no condition deduction unless the loss vehicle's documented condition is below average for its year/make/model (prior/unrelated damage may be deducted).	10 CCR § 2695.8(b)(2), (b)(3), (b)(4) checked Sep 4, 2026
Colorado	None. Colorado sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance. The only comparability constraint is that a replacement offered in kind must be of a 'comparable class', defined by vehicle type and passenger count.	3 CCR 702-5-2-15-4 (definitions); 3 CCR 702-5-2-15-5 (no comps standard) checked Sep 6, 2026
Connecticut partly verified	Connecticut's primary method is a published two-source retail average rather than a set of comparable listings, so there is no minimum count, radius, recency window or mileage tolerance attached to it. The Insurance Department's regulations separately describe auto total-loss settlement methods including a comparable automobile available in the local market, with comparables of like kind, quality, age, mileage and equipment and adjustments itemized in writing.	Conn. Gen. Stat. § 38a-353(a); Conn. Agencies Regs. § 38a-816-9 checked Sep 6, 2026
Delaware confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found.	18 Del. C. § 2304(16) (no comparable-vehicle standard) checked Sep 6, 2026
Florida	2 or more comparable vehicles in the 'local market area' available within the preceding 90 days; no mileage radius defined. Any deviation from the listed methods must be documented and deductions itemized in dollar amounts	Fla. Stat. § 626.9743(5)(a)1.; § 626.9743(5)(c) checked Sep 4, 2026
Georgia	2 or more comparable vehicles within 50 miles of the county seat where the vehicle was principally garaged, available within the last 30 days; if none, 2+ comps within 100 miles (incl. nearest major metro), then 2+ dealer quotes within 50 miles. No itemized-adjustment or written-explanation requirement in the rule	Ga. Comp. R. & Regs. R. 120-2-52-.06(a)1.-3. checked Sep 4, 2026
Hawaii	Hawaii constrains the SOURCES rather than the comparables. Dealer quotations may be used only when the vehicle is available at the quoting dealer's lot, and dealer quotations and newspaper advertisements may be used in lieu of the insurer's usual source but may NOT be treated as sole sources reflective of market value. Hawaii sets no minimum count, distance, recency window or mileage tolerance.	HRS § 431:10C-311(a)(2) checked Sep 6, 2026
Idaho confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found in Idaho law.	Idaho Code § 41-1329 (no comparable-vehicle standard) checked Sep 5, 2026
Illinois	Computerized-service comps: at least 2 vehicles currently available from, or sold by, licensed Illinois dealers (one sold within 30 days, one within 90 days), dealer located within 50 miles of the general metropolitan area; dealer names, locations and VINs kept in claim file. Database values must use data from the area where the vehicle was principally garaged with mileage/condition allowances. Betterment/condition deductions allowed only if measurable, itemized, specified in dollars and documented; wear-and-tear/rust/missing-parts deductions capped at $500; 'dealer prep' deductions prohibited.	50 Ill. Adm. Code 919.80(c)(2)(C); 919.80(d)(4)(A); 919.80(c)(3)(B) checked Sep 4, 2026
Indiana confirmed: no rule	None. Indiana sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	IC 27-4-1-4.5; 760 IAC 1 (no comparable-vehicle standard) checked Sep 13, 2026
Iowa	Two or more comparable automobiles in the local market area, available within 90 days. Where none is available locally, the insurer may go to proximate areas and the closest major metropolitan areas, still within 90 days. Iowa sets no distance in miles and no mileage tolerance, and does not define 'local market area'.	Iowa Admin. Code r. 191-15.43(1)(a)(2) checked Sep 5, 2026
Kansas	Comparables must come from the LOCAL MARKET AREA, which Kansas defines as the fifty-mile area surrounding where the vehicle was principally garaged. A valuation source must produce fair market values for a comparable automobile from current data available for that local market area, and must cover at least 85 percent of makes and models for the last 15 model years. Kansas sets no recency window and no mileage tolerance.	K.A.R. 40-1-34(q), adding § 9(j)(2); database criteria at (m)(B) checked Sep 6, 2026
Kentucky	A comparable motor vehicle must be in the local market area, and the dealer-quotation alternative needs two or more quotations from qualified and licensed dealers. Kentucky sets no distance in miles, no recency window and no mileage tolerance, and does not define 'local market area'.	806 KAR 12:095 § 7(1)(b) checked Sep 5, 2026
Louisiana	Comparables must come from a fair market value survey of qualified retail automobile dealers in the LOCAL MARKET AREA, with the nearest reasonable market permitted only where the local market has no dealers. Louisiana sets no minimum number of comparables, no distance in miles, no recency window and no mileage tolerance, and does not define 'local market area'.	La. R.S. 22:1892(A)(5) checked Sep 5, 2026
Maine confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found in the sections read.	24-A M.R.S. §§ 2436, 2436-A, 2907 (no comparable-vehicle standard) checked Sep 5, 2026
Maryland	A substantially similar motor vehicle must be the same make and model, of the same year as or a more recent year than the damaged vehicle, with mileage within the greater of 4,000 miles or 10 percent of the mileage on the damaged vehicle. The mileage limit does not apply where the vehicle is limited in production, specialty in nature, or older than 10 model years at the time of total loss.	COMAR 31.15.12.02B(7) checked Sep 5, 2026
Massachusetts	None. Massachusetts sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance. Comparability is expressed only as 'like kind and quality'.	211 CMR 133.05 (no comparable-vehicle standard) checked Sep 5, 2026
Michigan confirmed: no rule	None. Michigan has no distance, count, condition-similarity, or itemization requirement for comparable vehicles.	None found (Mich. Admin. Code, DIFS Insurance rules reviewed) checked Sep 4, 2026
Minnesota	A comparable automobile in the insured's local market area, adjusted for mileage, condition and options. Minnesota sets no minimum number of comparables, no distance or radius, and no recency window, and does not define 'local market area'.	Minn. Stat. § 72A.201 subd. 6(1)(b) checked Sep 5, 2026
Mississippi confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found in Mississippi law.	Miss. Code § 83-11-551 (no comparable-vehicle standard) checked Sep 5, 2026
Missouri	None. Missouri sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	20 CSR 100-1.050 (no comparable-vehicle standard) checked Sep 5, 2026
Montana	No comparable-vehicle standard. Montana prescribes the MEASURE — actual replacement value — rather than the method of arriving at it, so there is no minimum count, distance, recency window or mileage tolerance.	MCA § 33-23-202 (measure prescribed; no comparables standard) checked Sep 5, 2026
Nebraska confirmed: no rule	None. Nebraska sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	210 Neb. Admin. Code ch. 60, § 009 (no comparable-vehicle standard) checked Sep 5, 2026
Nevada	Two or more comparable automobiles that are currently available, or were available within the most recent 90 days, in the local market area. Only if there are not two there may the insurer extend the period or expand the area, and no further than necessary to find two. Dealer price quotations must come from two or more licensed dealers located within the local market area.	NAC 686A.680(1)(b)(1), (1)(b)(2) checked Sep 13, 2026
New Hampshire	No fewer than 2 documented SALES of the same make, model and year within the previous 90 days within the local market area, with like-kind-and-quality vehicles permitted only where exact matches are unavailable. Fair market value must then be adjusted to reflect the vehicle's condition, mileage, accessories and options. New Hampshire sets no distance in miles and does not define 'local market area'.	N.H. Admin. Code § Ins 1002.15(a)(2) checked Sep 5, 2026
New Jersey	A 'substantially similar vehicle' is one of the same make, model, year and condition including all major options, whose mileage does not exceed the insured vehicle's by more than 4,000 miles. A mileage difference above 4,000 may, AT THE INSURED'S OPTION, be exchanged for the presence or absence of options or a cash adjustment. Dealer quotations must come from within 25 miles of the principal place of garagement unless the insured agrees otherwise.	N.J.A.C. 11:3-10.2 (definitions); 11:3-10.4(a)2 checked Sep 5, 2026
New Mexico confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found in New Mexico law.	NMSA § 59A-16-20 (no comparable-vehicle standard) checked Sep 5, 2026
New York	'Substantially similar vehicle' = same make, model, year and condition, including all major options; mileage may not exceed the insured vehicle's by more than 4,000 miles or 10% of its mileage at date of loss, whichever is greater. Dealer-quote comps must come from a qualified dealer within 25 miles of the place of principal garagement, remain available for purchase for 3 calendar days after acknowledged notice, and the claim file must record dealer name/location, VIN, stock number, mileage and major options. 'Local market area' (for database valuations) = 100-mile radius of principal garagement, within the U.S.; database must draw on licensed dealers selling 100+ vehicles/year and physical inventory sold within 90 days before the loss. Deviation/explanation: manual-based offers require a detailed written calculation by payment date; any 'best available method' offer must be explained; the only expressly permitted line-item deductions are documented dealer prep (≤ $100), salvage value, and applicable deductions such as the deductible — Reg 64 has no CA-style 'discernible, measurable, itemized' condition-adjustment clause.	11 NYCRR § 216.7(a)(4), (a)(10), (c)(1)(i)-(iii), (c)(5) checked Sep 4, 2026
North Carolina	Comps must be same make, model, and year; located within a 100-mile radius of where the vehicle is principally garaged (expandable in 50-mile increments if none found); at least two; available (or available within 90 days of the accident) to consumers in that area. Adjustments allowed only for condition, options, equipment, mileage and unrepaired pre-existing damage; all deductions must be itemized with amounts and the supporting documentation shared with the claimant.	11 NCAC 04 .0418(b)(2), (b)(4), (d)(2), (e), (h) checked Sep 4, 2026
North Dakota confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found.	N.D.C.C. § 26.1-04-03(9) (no comparable-vehicle standard) checked Sep 13, 2026
Ohio	At least two comparable automobiles in the local market area that are or were available to consumers within the last 90 days; if none, comps from proximate areas including the closest in-state or out-of-state major metropolitan areas; then >=2 licensed-dealer quotes in the local market; database/guidebook only as a fallback with documented condition/mileage/option adjustments. Betterment, depreciation or comparative-negligence reductions must be itemized and specified in dollar amount on the written estimate and documented in the claim file; betterment allowed only for a measurable decrease in market value from poorer condition/prior damage or general wear, rust or missing parts, capped at the replacement cost of the affected parts. Claimant may not be required to travel an unreasonable distance to inspect a replacement vehicle.	Ohio Adm. Code 3901-1-54(H)(7)(a)-(d), (H)(2)-(3), (H)(8) checked Sep 23, 2026
Oklahoma	The cost of a comparable vehicle in the local market area, where one is currently or recently available within the prior 90 days. If none is available locally, one of two or more quotations from two or more qualified dealers located within the local market area. The statute sets no minimum number of comparables, no mileage tolerance and no definition of the local market area.	36 O.S. § 1250.8(A)(2)(a), (b) checked Sep 13, 2026
Oregon	A comparable replacement vehicle must be of the same make, of the same or a newer year, of a similar body style, with similar options and mileage, in as good or better overall condition, and available for inspection within a reasonable distance. Oregon sets no distance in miles, no minimum count and no recency window.	OAR 836-080-0240(2) checked Sep 5, 2026
Pennsylvania	No distance/market-radius or count-of-comps rule for the actual-cost method beyond: the comp must be 'available', of like kind and quality, in condition similar to or better than the insured vehicle, with its location specified in writing; dealer quotation method needs at least two quotes averaged; the appraiser's file must show the method used 'in a given locality'. Deductions are tightly limited: guide values adjusted only for equipment and mileage and pre-existing damage; no other deductions except salvage when owner retains the vehicle.	31 Pa. Code § 62.3(e)(1)(i)-(iii), (e)(6) checked Sep 4, 2026
Rhode Island	No comparable-vehicle standard of the usual kind — no minimum count, distance, recency window or mileage tolerance. What Rhode Island constrains instead is ADJUSTMENTS: any condition adjustment to the retail value must follow the standards of the same nationally recognized compilation the insurer used, and all adjustments including prior damage deductions must be itemized, fair and reasonable.	R.I. Gen. Laws § 27-9.1-4(29)(iv) checked Sep 6, 2026
South Carolina partly verified	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found in South Carolina law.	S.C. Code § 38-59-20 (no comparable-vehicle standard) checked Sep 5, 2026
South Dakota confirmed: no rule	None. South Dakota sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	SDCL 58-12-31 to 58-12-37; ARSD article 20:06 (no comparable-vehicle standard) checked Sep 13, 2026
Tennessee	Two or more comparable automobiles in the local market area, available now or within the last 90 days. Where none is available locally, the insurer may go to areas proximate to the local market area, including the closest major metropolitan areas within or outside Tennessee. 'Local market area' is NOT defined, so there is no radius; comparability turns on similarity including mileage.	Tenn. Comp. R. & Regs. 0780-01-05-.09(1)(a), (1)(b) checked Sep 5, 2026
Texas confirmed: no rule	None. No distance, count, age or itemization requirement for comparables in Texas statute or regulation	None located (see Tex. Ins. Code § 541.060(a)(3) for explanation-of-basis duty) checked Sep 4, 2026
Utah confirmed: no rule	None. Utah sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	Utah Admin. Code R590-190-12 (no comparable-vehicle standard) checked Sep 5, 2026
Vermont	Vermont DEFINES its terms, which almost no other state does. A 'comparable vehicle' is one of the same make and model, in similar or better condition, and NO OLDER than the totaled vehicle. 'Local market' means an area within a 75-MILE RADIUS of the zip code used to identify where the totaled vehicle was garaged. 'Available' means currently for sale, or available and/or sold within 90 days of the date of loss.	Vt. Reg. I-79-2 § 8(B)(2)(f)(i), (ii), (iii) checked Sep 5, 2026
Virginia	None. Virginia sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	14 VAC 5-400-80 (no comparable-vehicle standard) checked Sep 5, 2026
Washington	Comparables must be currently available or have been available within 90 days of the date of loss, with itemized and verifiable dollar amounts and appropriate additions or deductions for options, mileage or condition. The 150-mile limit attaches to the DEALER-QUOTATION method specifically — two or more licensed dealers within a reasonable distance of the principally garaged area, not to exceed 150 miles — and not to the comparable-vehicle method, which is stated as the area where the vehicle is principally garaged without a stated radius.	WAC 284-30-391(2)(b)(ii); (2)(b)(iv) checked Sep 5, 2026
West Virginia	A 'substantially similar vehicle' is one of the same make, model, year and condition, whose mileage may not exceed that of the insured vehicle by more than 4,000 miles unless mutually acceptable. West Virginia sets no distance in miles, no minimum count and no recency window.	W. Va. Code R. § 114-14-7.2.e checked Sep 5, 2026
Wisconsin confirmed: no rule	None. Wisconsin sets no minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance.	Wis. Admin. Code Ins 6.11 (no comparable-vehicle standard) checked Sep 5, 2026
Wyoming confirmed: no rule	None located. No minimum number of comparable vehicles, no distance or market-area limit, no recency window and no mileage tolerance was found in Wyoming law.	Wyo. Stat. § 26-13-124 (no comparable-vehicle standard) checked Sep 13, 2026

Three patterns are worth pulling out of that table, and which one you are in decides what kind of argument you are having.

A radius you can measure. A handful of states give a number. That is the strongest position there is, because "this comparable is 212 miles away and your rule says 50" is not a matter of opinion — it is arithmetic, and an adjuster cannot talk you out of it.

A market area with no number. Several states use a phrase like "local market area" without ever defining it. That absence is often conspicuous rather than accidental: a regulation can be precise about distances elsewhere and still decline to fix one here.

An insurer reaching across a state in one of these has not broken a numeric rule, so the argument is not "you exceeded 50 miles". It is whether the vehicle is genuinely from your market at all — which is a question about what a replacement would actually cost you, where you actually live.

No rule at all. In a large group of states nothing is prescribed about comparables. That sounds like bad news and mostly is, but it cuts both ways: an insurer has no rule to hide behind either. The argument moves to the policy's own actual-cash-value language and, in most of these states, to a statutory duty to give a reasonable explanation of the basis of the offer. That duty is the one worth leaning on, because a valuation built on comparables the insurer will not justify is an offer without a stated basis.

How many comparables the report has to carry

A smaller group of states puts a floor under the number of vehicles the average may be built from.

This matters more than it looks. If your state sets a floor and you can argue one comparable out of the average, the report may fall below the number the rule requires — at which point the insurer's position is not "a slightly lower value", it is that the valuation no longer satisfies the standard it was built to. Where there is no floor, the same argument still works, just more slowly: a two-car average with one bad car in it is a one-car valuation.

Mileage

Only one state in the ledger puts a number on how much more mileage a comparable may carry than your car.

Everywhere else, mileage is something the report is expected to adjust for rather than a disqualifier. That still gives you something, and it is a better argument than most people realize: if a comparable carries 30,000 more miles than yours and the report shows no mileage adjustment against it, the arithmetic is incomplete on its own terms. You do not need a rule about mileage to point out that a valuation compared two unlike things and then declined to account for the difference.

How recent a listing has to be

Every state that sets a window uses either 30 or 90 days, and the split is lopsided.

Two things follow. If you are in a state with a window, a listing older than it is simply outside the rule, and you can say so in one sentence. If you are in one of the many states with no window, a stale listing is still worth raising — used-car prices moved sharply enough between 2021 and 2024 that a six-month-old comparable is describing a different market, and a report that leans on one is making a claim about today's replacement cost using yesterday's evidence.

Either way, note the date beside every comparable before you argue anything else. Reports do not always print it prominently, and its absence is itself worth asking about: a comparable with no date is a comparable you cannot check.

Whether adjustments have to be itemized

This is the quiet one. A report can pick perfectly defensible comparables and still arrive at a low number by making adjustments it never explains — a lump "condition" deduction against each vehicle, no breakdown, no reasoning.

Where itemization is required, an unexplained adjustment is not a weak argument about fairness. It is a line the report was not entitled to take in that form, and the remedy you are asking for — show the working or remove it — is the one the rule already contemplates.

Where it is not required, you are back to the explanation duty: the insurer still has to be able to say why. In practice the request is identical. The difference is what happens when they refuse.

When a state has been read and sets no standard

A large group of states have had the section that would carry a comparable-vehicle standard opened and read, and it is not there. That is a finding rather than a gap, and it changes what you argue.

In those states the insurer has no numeric standard to comply with — and, equally, none to hide behind. It cannot tell you a comparable two hundred miles away is acceptable because the state permits it, because the state says nothing about distance at all. What it does have is a duty to reach a value that reflects what your car was actually worth, and a comparable drawn from a market you cannot buy in is evidence that it has not.

That argument is softer than quoting a radius, and it is worth being honest with yourself about the difference. But it is the argument the rules leave you, and it is the one this site's audit uses in those states — flagging a comparable that looks unreasonably far away against our own screening distance, labeled as ours rather than dressed up as the state's.

What to do with this

Take the comparables page of your report and check three things for each vehicle listed: how far away it is, how many miles it carries against yours, and when it was listed or sold. Any comparable that fails your state's test can be argued out of the average, and removing a cheap outlier moves the base value before a single adjustment is discussed.

Then check the adjustments column beside each comparable. A vehicle that survives on distance, mileage and date can still be dragged down by an adjustment nobody has justified, and those are argued the same way.

If two or more comparables survive, the recalculated average is your number. If fewer than two survive, the honest position is that the report has not established a value at all, and the thing to ask for is the complete valuation file plus the chance to supply your own listings. That is a stronger place to be than it sounds: you are no longer negotiating against their number, you are pointing out that they do not have one yet.