HI| The Hawaii Insurance Commissioner’s Memorandum 2025-9A clarifies the insurance requirements for peer-to-peer (P2P) car-sharing under Hawaii law. The memorandum states that a P2P car-sharing program is responsible for ensuring that primary motor vehicle insurance coverage exists during each car-sharing period, as required by Hawaii Revised Statutes §431:10C-802(a). However, the law does not require the program itself to be the insurer unless other available insurance from the vehicle’s owner or driver lapses, excludes, or does not meet statutory requirements, at which point the program must provide necessary coverage. The agreement between the parties must clearly identify which party is responsible for providing primary insurance, and any ambiguity will be construed against the program. The program also has a duty to disclose any insurance exclusions in writing to the car owner and driver during the sharing period.HI-Commissioners-Memo-2025-9A-P2P-Car-Sharing_signed.pdf
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