STATE LAW / STORAGE FEES

Who pays storage on a total loss, and what can a shop charge?

What the law says in 22 states about insurers paying storage, the notice owed before storage payments stop, and what a shop or storage lot may charge. Every quote is the law's own words, with a link to the official source.

The short answer

Many of these states put a duty on the insurer: pay reasonable storage, or give notice and time to move the car before storage payments stop. The notice ranges from 72 hours in Florida to three working days in New Jersey, five calendar days in Washington, and "reasonable" notice in others.

On the shop side, many states require the storage charge to be disclosed up front, on the estimate, the repair authorization or a posted sign, and some tie storage liens to notice to the owner or lienholder. Several dollar caps apply only to tow and storage lots; the table labels those. 22 of 22 states have a provision in our collection on at least one side.

Who pays storage on a total loss, and what can a shop charge?: what each state's law says
StateWhat it meansThe law's own words
ArizonaAll Arizona rulesNo rule in our Arizona collection makes the insurer pay storage or give notice before it stops. You have a lien for storage only when you and the owner agreed on the charges. If a car becomes abandoned at your shop and you don't report it to the state within the following 30 days, you lose all claims for towing, repair estimates and storage. Towing companies on accident tows have no lien for unpaid towing or storage.

A.R.S. § 28-4847 applies to tows that result from motor vehicle accidents and binds towing companies, not repair shops. No rule in our Arizona collection requires an insurer to pay storage or give notice before it stops.

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“Proprietors of garages and repair and service stations shall have a lien upon motor vehicles of every kind and aircraft, and the parts and accessories placed thereon, for labor, materials, supplies and storage for the amount of the charges, when the amount of the charges is agreed to by the proprietor and the owner.”

A.R.S. § 33-1022, azleg.gov text, 2026 session update
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“an operator of a repair facility who fails to make the report to the director by the end of the succeeding thirty days forfeits all claims for towing, repair estimates or storage of the vehicle.”

A.R.S. § 28-4840, azleg.gov text, 2026 session update
Tow and storage lot

“If the towing company fails to provide a detailed list of charges by the close of business on the day of the request, the towing company shall not assess any storage charges on subsequent days until the day that the towing company provides the detailed statement of charges to the owner or insurance company.”

A.R.S. § 28-4847, azleg.gov text, 2026 session update
Tow and storage lot

“A lien does not exist in favor of a towing company or storage lot for unpaid towing or storage fees or charges that are incurred.”

A.R.S. § 28-4847, azleg.gov text, 2026 session update
CaliforniaAll California rulesAfter a covered collision or physical damage loss, the insurer must pay reasonable towing and storage needed to protect the car, including on third-party claims, where payment can be reduced by fault. Before it stops paying storage, it must give your customer reasonable notice and time to move the car; no number of days is set. Storage you charge the lender or lessor on the title must be reasonable; after 15 days, it runs only from 3 days after your certified-mail notice to them.

Vehicle Code 10652.5 limits storage charged to the legal owner, meaning the lienholder or lessor, not the registered owner. The insurer rule also covers third-party claims, where payment may be prorated by fault.

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“no fee or service charge may be imposed upon the legal owner for the parking and storage of the motor vehicle except as follows: (1) The first 15 days of possession and (2) following that 15-day period, the period commencing 3 days after written notice is sent by the person in possession to the legal owner by certified mail, return receipt requested”

Cal. Veh. Code 10652.5, effective 1/1/2026
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“All storage and towing fees charged to a legal owner of a motor vehicle shall be reasonable. The following rates and fees are presumptively unreasonable:”

Cal. Veh. Code 10652.5, effective 1/1/2026
Insurer

“After a covered loss under a policy of automobile collision coverage or automobile physical damage coverage as defined in California Insurance Code Section 660 , where towing and storage are reasonably necessary to protect the vehicle from further loss, the insurer shall pay reasonable towing and storage charges incurred by the claimant.”

10 CCR 2695.8, effective 1/1/2017 (Cornell LII copy)
Insurer

“The insurer shall provide reasonable notice to the claimant before terminating payment for storage charges, so that the claimant has time to remove the vehicle from storage.”

10 CCR 2695.8, effective 1/1/2017 (Cornell LII copy)
ColoradoAll Colorado rulesNo rule in our Colorado collection says the insurer must give notice before it stops paying storage. It must tell the insured or claimant what towing and storage the policy pays and warn about extra charges they may owe. Your storage rates must be printed clearly on a separate written authorization, and storage can't start until 3 days after you tell the customer the car is done, not counting weekends, holidays or days you're closed. You have a lien for reasonable storage charges.

The repair-facility rules (CRS 42-9-104 and 42-9-106) govern storage a customer agrees to in writing. No rule in our Colorado collection requires an insurer to give notice before it stops paying storage.

Insurer

“An insurer shall clearly disclose to an insured or inform a third-party claimant what benefits are provided related to towing and storage of a motor vehicle that sustains property damage and shall specifically advise an insured or third-party claimant concerning excess charges that may be incurred related to towing and storage of a motor vehicle for which the insured or third-party claimant may be responsible.”

CRS 10-4-639, 2026 edition
Shop

“The amounts that a customer may be charged for storage charges shall be conspicuously printed on the separate written authorization provided to the customer.”

CRS 42-9-104, 2026 edition
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“No charge shall be made for storage of the motor vehicle unless the motor vehicle is not picked up by the customer within three days, exclusive of Saturday, Sunday, legal holidays, and any days the repair facility is closed for business, after the customer is notified that the repairs have been completed and the customer was notified, as required by section 42-9-104 (2)(a), that such storage charges would accrue.”

CRS 42-9-106, 2026 edition
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“every other person who safely keeps or stores any personal property at the request of the owner or person lawfully in possession of the personal property has a lien upon the personal property for reasonable charges for the transportation, storage, or keeping of the personal property”

CRS 38-20-105, 2026 edition
FloridaAll Florida rulesBefore the insurer stops paying storage it already authorized, it must give your customer, the insured, notice and 72 hours to move the car. On jobs over $150, your estimate must state the daily storage charge, and storage can't start until 3 working days after you tell the customer the car is done. If you enforce a lien by sale, notify the owner, customer and lienholders within 7 business days after storage starts, or you can charge an unnotified lienholder for only 7 days.

The estimate rule applies to repair work over $150; the lien-notice rows apply to a shop enforcing a repair lien by sale. Tow-yard storage is governed separately by Fla. Stat. 713.78.

Insurer

“Every insurer shall provide notice to an insured before termination of payment for previously authorized storage charges, and the notice shall provide 72 hours for the insured to remove the vehicle from storage before terminating payment of the storage charges.”

Fla. Stat. 626.9743, 2026 edition
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“A statement indicating the daily charge for storing the customer’s motor vehicle after the customer has been notified that the repair work has been completed. However, storage charges may not accrue or be due and payable for a period of 3 working days from the date after such notification.”

Fla. Stat. 559.905, 2026 edition
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“Be sent to the registered owner, the customer, and all other persons claiming an interest therein or lien thereon within 7 business days, excluding Saturday and Sunday, after the date on which storage charges begin to accrue on the vehicle.”

Fla. Stat. 713.585, 2026 edition
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“If a lienor fails to provide notice to any person claiming a lien on a vehicle under subsection (1) within 7 business days after the date of storage of the vehicle, the lienor may not charge the person for more than 7 days of storage”

Fla. Stat. 713.585, 2026 edition
GeorgiaAll Georgia rulesOnce the insurer accepts liability, it must pay the third-party claimant's reasonable towing and storage, total losses included, but only actual losses, and the claimant must still keep costs down. This covers policies issued or renewed since January 1, 2009; no rule in our Georgia collection sets a notice period before payment stops. Your storage lien exists only after you meet the statute's notice requirements, and it counts storage at the Department of Public Safety's maximum daily rate from when your notice was received.

The insurer rule covers third-party liability claims under policies issued or renewed on or after January 1, 2009. Georgia statute text is from the 2019 official release; confirm it is current.

Insurer

“Any insurer, upon acceptance of liability, pursuant to any automobile liability or motor vehicle liability insurance policy, shall pay reasonable benefits for losses, including total losses, to a third party on behalf of an insured for loss of use and towing and storage costs of such a motor vehicle”

O.C.G.A. 33-7-11.1, 2019 official release (public.resource.org copy)
Insurer

“provided, however, in no event shall this Code section be construed so as to relieve the claimant of his or her obligation to mitigate his or her losses or to require the payment of loss of use and towing and storage costs benefits in an amount which is greater than the actual losses suffered.”

O.C.G.A. 33-7-11.1, 2019 official release (public.resource.org copy)
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“Any towing and storage firm, repair facility, or salvage dealer shall have a lien on a motor vehicle located on its property in the amount of any unpaid and incurred fees upon compliance with the notice requirements of this Code section.”

O.C.G.A. 40-11-19, 2019 official release (public.resource.org copy)
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From a list that begins: “Fees that have actually been incurred by any towing and storage firm, repair facility, or salvage dealer and which are documented to the court are recoverable under such lien and shall be limited to the following:”

“For a repair facility or salvage dealer, the maximum allowable daily rate for the storage of the motor vehicle as set forth by rule and regulation of the Department of Public Safety for maximum state-wide rate tariffs multiplied by the number of days such motor vehicle has been stored from the date notification required under this Code section was received to the date any judgment is issued plus 25 days;”

O.C.G.A. 40-11-19, 2019 official release (public.resource.org copy)
IllinoisAll Illinois rulesBefore the insurer stops paying storage, it must give your customer, the insured, enough notice to move the car and note it in the claim file. It also can't abandon a salvage car to a tow or storage yard in place of paying the bill unless the yard agrees. On your side, send certified-mail notice to the lender on the title before any storage fees start. Skip it and you can't collect storage, and the lender can get the car back without paying any.

The lienholder-notice rule does not apply to a municipality of 1,000,000 or more seeking storage fees. The insurer notice runs to an insured.

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“Any person, firm, or private corporation seeking to impose fees in connection with the furnishing of storage for a vehicle in the person's, firm's, or corporation's possession must provide written notice, by certified mail, return receipt requested, to the lienholder of record prior to the assessment and accrual of such fees, regardless of whether it enforces a lien under this Act.”

770 ILCS 45/1.5, effective 11/23/2017
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“If a person, firm, or private corporation fails to comply with the notification requirements set forth in subsection (a) of this Section, storage fees shall not be assessed and collected and the lienholder shall be entitled to injunctive relief for possession of the vehicle without the payment of any storage fees.”

770 ILCS 45/1.5, effective 11/23/2017
Insurer

“The company shall provide reasonable notice to an insured prior to termination of payment for automobile storage charges and document such notice in the claim file. Reasonable notice shall constitute sufficient notice to the insured to allow them to remove the vehicle from storage prior to the termination of payment.”

50 Ill. Adm. Code 919.80, effective 7/22/2002
Insurer

“No company issuing a motor vehicle insurance policy covering damages to a motor vehicle shall abandon the salvage of a motor vehicle to a towing service and/or storage yard service in lieu of the towing and storage charges, without the agreed permission of the towing service or storage yard service.”

50 Ill. Adm. Code 919.90, effective 1/11/1989
IndianaAll Indiana rulesNo rule in our Indiana collection requires the insurer to pay storage or give notice before it stops. If you store or repair a car at the owner's request, you have a lien for reasonable storage charges. Under the repair and storage lien statute, storage costs can't exceed $1,500, and storage on an abandoned vehicle is generally capped at $2,000. A towing service that doesn't notify the owner or lender as required can't collect storage that builds up after it gets their address.

The $1,500 limit is in the repair and storage lien statute. No rule in our Indiana collection requires an insurer to pay storage or give notice before it stops.

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“A person that performs labor, furnishes materials or storage, or does repair work on a vehicle at the request of the owner of the vehicle has a mechanic's lien on the vehicle for the reasonable value of the charges for the labor, materials, storage, or repairs.”

IC 9-22-6-2, Indiana Code 2026 edition
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“The costs of storing a motor vehicle may not exceed one thousand five hundred dollars ($1,500).”

IC 32-33-10-5, Indiana Code 2026 edition
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“Except as provided in subsection (c), the costs for storage of an abandoned vehicle may not exceed two thousand dollars ($2,000).”

IC 9-22-1-4, Indiana Code 2026 edition
Tow and storage lot

“Notwithstanding section 4 of this chapter, a public agency or towing service that fails to notify the owner of or lienholder on the vehicle as set forth in this subsection may not collect additional storage costs incurred after the date of receipt of the name and address obtained.”

IC 9-22-1-19, Indiana Code 2026 edition
MarylandAll Maryland rulesNo rule in our Maryland collection requires the insurer to pay storage or give notice before it stops. You have a lien for storage when the owner left the car with you and asked for the work. If you hand a car you hold a lien on to someone else to store, their fees can't exceed $5 a day or $300 total. If a car is abandoned at your garage, report it within 10 days or lose any claim for service, storage or repair.

The parking-lot tow limits yield to local law. No rule in our Maryland collection requires an insurer to pay storage or give notice before it stops.

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“Any person who, with the consent of the owner, has custody of a motor vehicle and who, at the request of the owner, provides a service to or materials for the motor vehicle, has a lien on the motor vehicle for any charge incurred for any: (i) Repair or rebuilding; (ii) Storage; or”

Md. Code, Com. Law § 16-202, mgaleg.maryland.gov text in effect as of 10/1/2026
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“If property is stored, storage fees of the third party holder may not exceed $5 per day or a total of $300.”

Md. Code, Com. Law § 16-207, mgaleg.maryland.gov text in effect as of 10/1/2026
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“Any garage keeper who fails to report the vehicle within 10 days after it becomes abandoned no longer has any claim for servicing, storage, or repair of the vehicle.”

Md. Code, Transp. § 25-208, mgaleg.maryland.gov text in effect as of 10/1/2026
Tow and storage lot

From a list that begins: “Unless otherwise set by local law, a person who undertakes the towing or removal of a vehicle from a parking lot:”

“If a political subdivision does not establish a fee limit for the public safety towing, recovery, or storage of impounded vehicles, $250 for towing and recovering a vehicle and $30 per day for vehicle storage; and”

Md. Code, Transp. § 21-10A-04, mgaleg.maryland.gov text in effect as of 10/1/2026
MassachusettsAll Massachusetts rulesNo rule in our Massachusetts collection makes the insurer pay storage or sets a notice period before it stops. If you give the insurer written notice of your lien, its check for your charges must name you as a payee, along with any lender. A car can't be moved to a holding area as a total loss without the owner's consent. Before repairs are authorized, tell the customer when you charge storage and the rate; a clear sign at your shop counts.

The loss-payee rule applies when an insurer pays or reimburses the garage's charges. The storage disclosure is met if the shop posts it clearly on its premises.

Shop

“Persons maintaining public garages for the storage and care of motor vehicles brought to their premises or placed in their care by or with the consent of the owners thereof and persons engaged in performing work upon or in connection with the inspection, reconditioning and repairing of motor vehicles shall have a lien upon such motor vehicles for proper charges due them for the storage, work and care”

M.G.L. c. 255, § 25, General Laws text with amendments passed before 5/31/2026
Insurer

“upon written notice by the holder of such lien to the insurance company, the check or draft issued by such insurance company for such charges shall name the holder of the lien, together with the holder of a security interest as defined by ARTICLE 9 of chapter one hundred and six, as a loss payee, unless otherwise provided by law.”

M.G.L. c. 255, § 25, General Laws text with amendments passed before 5/31/2026
Shop

“It is an unfair or deceptive act or practice for a repair shop to fail to inform a customer, prior to obtaining oral or written authorization to perform repairs on the customer's vehicle, of the following information: (a) The conditions under which the repair shop may impose storage charges and the daily or hourly amount of such charges;”

940 CMR 5.05, mass.gov date 7/9/2004
Insurer

“No motor vehicle may be deemed a total loss unless it has been inspected or appraised by a licensed appraiser nor shall any such motor vehicle be moved to a holding area without the consent of the owner.”

212 CMR 2.04, mass.gov date 9/9/2008
MichiganAll Michigan rulesThe one insurer storage rule in our Michigan collection, which makes the insurer pay towing and storage from when the claim is reported until it's paid, covers only creditor-placed insurance. You can't charge storage while the repair bill is in dispute. If a parts delay holds up the job, you can charge storage only after telling the customer the expected delay and the daily rate and getting their OK. Unless agreed in writing, your lien can include no more than $10 a day for storage.

The insurer rule, MCL 500.1619, applies to creditor-placed insurance only. The lien storage limits apply unless otherwise agreed in writing.

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From a list that begins: “shall not, directly or through an agent or employee, do any of the following:”

“Charge a customer storage charges if there is a dispute concerning repair charges.”

MCL 257.1307e, effective 4/4/2017
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“If a delay in repairs is caused by a lack of parts, a facility may charge for storage after informing the customer of the approximate length of the anticipated delay and of the daily storage charge rate and obtaining the customer's consent to the delay and the storage charges.”

MCL 257.1307e, effective 4/4/2017
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“Unless otherwise agreed to in writing, a garage keeper's lien under section 3 may include an amount of not more than $10.00 per day for the storage of the vehicle, for the storage of an accessory used in the operation of a vehicle, or for the storage of accessories and supplies furnished for the vehicle or an accessory used in the operation of the vehicle.”

MCL 570.304, effective 7/1/2002
Insurer

“The insurer shall be responsible for the payment of towing and storage charges for a covered loss occurrence from the time the claim is reported to the insurer in accordance with the terms of the policy to the time the claim is paid.”

MCL 500.1619, effective 3/23/2003
MinnesotaAll Minnesota rulesNo rule in our Minnesota collection requires the insurer to pay storage or give notice before it stops. You have a lien for storage, but if a lender is listed on the title, your lien covers storage past 15 days only after you send that lender certified-mail notice. On consumer repairs over $100, tell the customer with the written estimate that storage is extra, and post a sign showing your storage charge, when it starts and how often it's charged.

The disclosure rules apply to consumer repairs over $100. No rule in our Minnesota collection requires an insurer to pay storage or give notice before it stops; § 72A.201 mentions towing but not storage.

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“Whoever, at the request of the owner or legal possessor of any personal property, shall store or care for or contribute in any of the modes mentioned in section 514.19 to its preservation, care, or to the enhancement of its value, shall have a lien upon such property for the price or value of such storage, care, or contribution”

Minn. Stat. § 514.18, 2025 edition
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“If the property subject to the lien is a motor vehicle registered in this state and subject to a certificate of title and one or more secured creditors is listed on the certificate of title, a lien for storage charges for a period greater than 15 days accrues only after written notice is sent by certified mail to all listed secured creditors.”

Minn. Stat. § 514.19, 2025 edition
Shop

“At the time a shop provides a customer with a written estimate, the shop shall inform the customer that any charge for storage or care, a service call or a charge for making an estimate shall be in addition to the estimated price for the repairs.”

Minn. Stat. § 325F.58, 2025 edition
Shop

“If the shop charges a fee for the storage or care of repaired motor vehicles or appliances, the shop shall conspicuously display a sign that states the amount assessed for storage or care, when the charge begins to accrue, and the interval of time between assessments.”

Minn. Stat. § 325F.62, 2025 edition
MissouriAll Missouri rulesThe one insurer storage rule in our Missouri collection covers only abandoned cars towed under police authority: the insurer pays the lot's reasonable fees up to its coverage, and the car must be claimed or titled to the lot within 30 days after the later of the total-loss payment or the insurer learning where it is. Your storage lien needs the daily rate in the owner's written request. Report a car unclaimed 15 days within 5 more days or lose your storage claims and liens.

The insurer rule covers only abandoned vehicles removed under RSMo 304.155 or 304.157.

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“where the maximum amount to be charged for labor, services, skill or material has been stated as part of the written request or the daily charge for storage has been stated as part of the written request, have a lien upon the chattel beginning upon the date of commencement of the expenditure of labor, services, skill, materials or storage”

RSMo 430.082, effective 8/28/2012
Insurer

“The owner of the abandoned vehicle, lienholder or insurer, to the extent the vehicle owner's insurance policy covers towing and storage charges, shall pay reasonable fees assessed by the towing company and storage facility.”

RSMo 304.156, effective 1/1/2005
Insurer

“The property shall be claimed and removed or title transferred to the towing company or storage facility within thirty days of the date that the insurer paid a claim for the total loss of the property or is notified as to the location of the abandoned property, whichever is the later event.”

RSMo 304.156, effective 1/1/2005
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“Any dealer or person operating a public garage who fails to report a motor vehicle as unclaimed as herein required forfeits all claims and liens for its garaging, parking or storing.”

RSMo 301.280, effective 8/28/2021
MontanaAll Montana rulesNo rule in our Montana collection requires the insurer to pay storage or give notice before it stops. While you lawfully hold the car, you have a lien for the reasonable cost of storage. If the customer asks for a written estimate, it must include any storage costs. Tow truck operators who remove a wreck from a public road at police request must send the owner or lender a certified letter within 15 days.

No rule in our Montana collection requires an insurer to pay storage or give notice before it stops. The certified-letter rule covers only law-enforcement tows from a public roadway.

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“A person who, while lawfully in possession of an article of personal property, product, or commodity renders any service to the owner or lawful claimant of the article by labor or skill employed for the making, repairing, protection, improvement, safekeeping, carriage, towing, or storage of the article or tows or stores the article as directed under authority of law has a special lien on the article.”

MCA 71-3-1201, 2025 edition
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“If the service is towing or storage, the lien is for the reasonable cost of the towing or storage.”

MCA 71-3-1201, 2025 edition
Tow and storage lot

“Within 15 days after the date that a wrecked or disabled vehicle is removed from a public roadway by a qualified tow truck operator at the request of a law enforcement officer under 61-8-908, the qualified tow truck operator shall send a certified letter to the vehicle owner or lienholder”

MCA 61-8-913, 2025 edition
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“If a written estimate is requested, the motor vehicle repair business shall give to the customer a written, estimated price for labor, parts necessary for the specific job, storage costs (if any) and the approximate date of work completion.”

ARM 23.19.202, effective 2/10/2006
New JerseyAll New Jersey rulesBefore the insurer stops paying storage, it must give the claimant 3 working days' notice and keep a copy in the claim file. If you charge to store a car, tell the customer the daily storage charge in writing as soon as you can. You have a garage keeper's lien for storage. Separately, a towing company on a police-authorized tow that doesn't notify the owner and lender within 30 days can charge no more than $750 for storage.

The two N.J.A.C. rows are quoted from Cornell LII's copy of the New Jersey Administrative Code (the official code is published commercially); confirm against the official code. The $750 cap applies to non-consensual tows authorized by law enforcement.

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“A garage keeper who shall tow, store, maintain, keep, or repair a motor vehicle or furnish gasoline, accessories or other supplies therefor, at the request or with the consent of the owner or the owner's representative, or at the request of a law enforcement officer of this State or any political subdivision of this State, shall have a lien upon the motor vehicle or any part thereof”

N.J.S.A. 2A:44-21, text through P.L.2026, c.50
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“Every auto body repair facility that charges a fee to store a motor vehicle on its premises shall disclose in writing, as soon as practicable, the amount of such storage charge to the customer on a per diem basis.”

N.J.A.C. 13:21-21.14, amended effective 1/16/2001 (Cornell LII copy)
Insurer

“An insurer shall provide notice to a claimant three working days prior to the termination of payment for automobile storage charges and place a copy of such notice in a claim file.”

N.J.A.C. 11:2-17.10(a)9 (Cornell LII copy)
Tow and storage lot

“If a towing company fails to notify the operator, owner, lessor, and lienholder of the vehicle within 30 days, the towing company may charge a maximum storage fee of $750, and the towing company shall be responsible for all additional towing or related storage services.”

N.J.S.A. 56:13-16, text through P.L.2026, c.50
New YorkAll New York rulesNo rule in our New York collection requires the insurer to pay storage or give notice before it stops; the state's claim rule, 11 NYCRR 216.7, has no storage provision. You can't charge storage unless you've told the customer in writing, such as a line on the estimate. No storage can run from when the customer authorizes repairs until one business day after you tell them to pick it up. If you gave a written estimate, your lien can't exceed it.

No rule in our New York collection requires an insurer to pay storage or give notice before it stops; 11 NYCRR 216.7 has no storage provision. Lien Law notice deadlines for owners and lienholders apply to police-requested tows.

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“However, if the bailee of a motor vehicle, motor boat or aircraft has furnished a written estimate of the cost of towing, storage, maintenance, repair or any other service on such motor vehicle, motor boat or aircraft, any lien sought by such bailee for such service may not be in an amount in excess of the written estimate.”

N.Y. Lien Law 184, revised 9/22/2014
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“A customer may not be charged for storage unless notice in writing is given. Notice may be given by a statement on an estimate or other document given the customer, by letter or by other written means which gives the customer actual notice.”

15 NYCRR 82.8, CR-82 (5/26) (PDF)
Shop

“Storage may not be charged during the period from which the customer has authorized repairs to one business day after the repair shop has notified the customer to pick up the repaired vehicle.”

15 NYCRR 82.8, CR-82 (5/26) (PDF)
North CarolinaAll North Carolina rulesOn a total loss, the insurer is responsible for reasonable towing and storage until 3 days after it tells the owner and the storage facility in writing that it will stop paying. It also can't abandon the salvage to a tow or storage business without that business's consent. On jobs over $350, unless the customer waives the estimate in writing, your estimate must state the daily storage charge after the work is done. You have a lien for reasonable storage charges.

The insurer rule is a total-loss rule. The estimate rule applies to repair work over $350 unless the customer waives the estimate in writing.

Shop

“The written repair estimate shall also include a statement allowing the customer to indicate whether replaced parts should be saved for inspection or return and a statement indicating the daily charge for storing the customer's motor vehicle after the customer has been notified that the repair work has been completed.”

G.S. 20-354.3, ncleg.gov text through S.L. 2026-30
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“Any person who repairs, services, tows, or stores motor vehicles in the ordinary course of the person's business pursuant to an express or implied contract with an owner or legal possessor of the motor vehicle, except for a motor vehicle seized pursuant to G.S. 20-28.3, has a lien upon the motor vehicle for reasonable charges for such repairs, servicing, towing, storing”

G.S. 44A-2, ncleg.gov text through S.L. 2026-30
Insurer

“The insurance company shall be responsible for all reasonable towing and storage charges until three days after the motor vehicle's owner and storage facility are notified in writing that the insurance company shall no longer reimburse the motor vehicle's owner or storage facility for storage charges.”

11 NCAC 04 .0418, effective 10/1/2020
Insurer

“No insurance company shall abandon the salvage of a total loss motor vehicle to a towing or storage service without the consent of the towing or storage service involved.”

11 NCAC 04 .0418, effective 10/1/2020
OhioAll Ohio rulesBefore the insurer stops paying storage, it must notify the claimant, but no number of days is set. The insurer can sue a tow or storage company to get a car back or challenge its bill. If a car worth under $3,500 sits unclaimed 15 days after the repair is done, you must send the owner and any lender a notice to remove it. Lots holding cars under ORC 4513.60 and 4513.601 can charge at most $22 a day for vehicles rated under 10,001 pounds.

The insurer notice runs to "a claimant." The $22-a-day cap applies only to vehicles towed or stored under ORC 4513.60 and 4513.601 (effective January 1, 2026).

Shop

“Any repair garage or place of storage in which a motor vehicle with a value of less than three thousand five hundred dollars has been left unclaimed for fifteen days or more following completion of the requested repair or the agreed term of storage shall send a notice to remove the motor vehicle to the last known address of any owner and any lienholder of the motor vehicle.”

ORC 4505.101, effective 4/7/2023
Insurer

“An insurance company may commence a civil action against a towing service or storage facility on its own behalf, on behalf of the holder of a policy of automobile insurance, or on behalf of a motor vehicle owner for either or both of the following reasons: (a) The recovery of a motor vehicle that has been towed or stored and for which a claim has been filed with the insurance company; (b) Objecting to the amount billed by the towing service or storage facility.”

ORC 4513.70, effective 6/30/2017
Insurer

“An insurer shall provide notice to a claimant prior to termination of payment for automobile storage charges.”

OAC 3901-1-54, effective 2/14/2022
Tow and storage lot

“If a motor vehicle has a manufacturer's gross vehicle weight rating less than ten thousand one pounds, any fee for the storage of the vehicle charged by a storage facility pursuant to sections 4513.60 and 4513.601 of the Revised Code shall not exceed the reasonable cost of complying with the requirements of those sections, but in no instance exceed twenty-two dollars per day.”

OAC 4901:2-24-03, effective 1/1/2026
PennsylvaniaAll Pennsylvania rulesThe insurer's written appraisal must list storage and other incidental charges known then, plus any date after which the insurer won't pay towing or storage and your customer becomes responsible. No rule in our Pennsylvania collection sets a minimum notice period. The appraiser needs the customer's consent before having the car moved, except the first tow from the accident scene. Before the customer authorizes repairs, you must tell them when you charge daily or hourly storage and how much.

The insurer items are disclosures required in the written appraisal. Consent is not needed for the first removal from the accident scene.

Insurer

“The date, if any, after which an insurer will not be responsible for any related towing services or storage charges, known at the time of appraisal, and after which the charges will be the responsibility of the consumer.”

31 Pa. Code 62.3, effective 10/23/1999
Insurer

“Incidental charges, known at the time of appraisal, including towing, protective care, custody, storage, depreciation, battery and tire replacement.”

31 Pa. Code 62.3, effective 10/23/1999
Insurer

“Obtain the consumer’s consent before authorizing the removal of a motor vehicle from one location to another.”

31 Pa. Code 62.3, effective 10/23/1999
Shop

From a list that begins: “With regard to a repair shop, the following is considered unfair methods of competition and unfair or deceptive acts or practices:”

“The conditions under which the repair shop may impose daily or hourly storage charges for a vehicle and the amount of the charges.”

37 Pa. Code 301.5
TennesseeAll Tennessee rulesBefore the insurer stops paying storage, it must give your customer, the insured, reasonable notice and time to move the car. Session-law text bars charging storage past 21 days without the owner's or lender's consent unless they refused to pick up a ready car or you gave the required notice; that limit doesn't cover a car you were authorized to repair once the owner is told it's done. You can't charge storage for days the car isn't available for release, except a police hold.

Statute rows are session-law text. A 2026 amendment (Public Chapter 661, effective July 1, 2026) exempts storage of a vehicle held for authorized repairs after the owner is told the work is done. The insurer notice runs to an insured.

Shop

“Garagekeepers are entitled to a lien upon all motor vehicles that lawfully come into their possession and are retained in their possession until all reasonable charges due are paid.”

Tenn. Pub. Ch. 1017 (2024), § 5 (T.C.A. 66-19-103), session-law text (PDF)
Shop

“Except as otherwise provided in this section, a garagekeeper shall not charge the owner or lienholder of a stored motor vehicle a storage fee for a period exceeding twenty-one (21) days without the consent of the owner or lienholder, unless the owner or lienholder has been notified that the motor vehicle is available to be released from the garagekeeper and the owner or lienholder refuses to retrieve the motor vehicle.”

Tenn. Pub. Ch. 457 (2025), § 1 (T.C.A. 55-31-207), session-law text (PDF)
Shop

“A garagekeeper shall not charge a storage fee for any day on which the motor vehicle is not available for release to the owner, lienholder, or insurer, unless the failure to release is based on a hold placed on the motor vehicle by law enforcement.”

Tenn. Pub. Ch. 457 (2025), § 1 (T.C.A. 55-31-207), session-law text (PDF)
Insurer

“The insurer shall provide reasonable notice to an insured prior to termination of payment for reasonable automobile storage charges and documentation of the denial as required by rule 0780-01-05-.05. Such insurer shall provide reasonable time for the insured to remove the vehicle from storage prior to the termination of payment, subject to any applicable policy provisions.”

Tenn. Comp. R. & Regs. 0780-01-05-.09, effective 10/9/2017 (PDF)
TexasAll Texas rulesAn insurer that pays a total loss on a car at a vehicle storage facility owes the facility its charges, even storage from before payment. Those facility rules, with daily caps like $20 for vehicles up to 25 feet, don't cover a car stored with the owner's consent. No rule in our Texas collection requires notice before the insurer stops paying storage. Holding a car for a reason other than repair earns reasonable storage, but only 5 days until you mail the required notice.

Occupations Code chapter 2303 states it does not apply to a vehicle stored with the owner's consent. The daily fees can be adjusted by rule. No rule in our Texas collection requires an insurer to give notice before it stops paying storage.

Insurer

“An insurance company that pays a claim of total loss on a vehicle in a vehicle storage facility is liable to the operator of the facility for any money owed to the operator in relation to delivery of the vehicle to or storage of the vehicle in the facility regardless of whether an amount accrued before the insurance company paid the claim.”

Tex. Occ. Code 2303.156, effective 6/1/2003
Tow and storage lot

“(3) a daily storage fee, subject to Section 2303.1552, of: (A) $20 for each day or part of a day the vehicle is stored at the facility if the vehicle is not longer than 25 feet; or (B) $35 for each day or part of a day the vehicle is stored at the facility if the vehicle is longer than 25 feet; and”

Tex. Occ. Code 2303.155, effective 6/14/2019
Tow and storage lot

“The operator of a vehicle storage facility who receives a vehicle that is registered in this state and that is towed to the facility for storage shall send a written notice to the registered owner and the primary lienholder of the vehicle not later than the fifth day after the date but not earlier than 24 hours after the date the operator receives the vehicle.”

Tex. Occ. Code 2303.151, effective 6/15/2017
Shop

“A garagekeeper who acquires custody of a motor vehicle for a purpose other than repair is entitled to towing, preservation, and notification charges and reasonable storage fees, in addition to storage fees earned under a contract, for each day: (1) not to exceed five days, until the notice described by Section 683.031(a) is mailed; and”

Tex. Transp. Code 683.032, effective 9/1/1997
VirginiaAll Virginia rulesBefore the insurer stops paying storage, it must give the claimant reasonable notice and reasonable time to move the car, with no set number of days. You have a lien for towing and storage until you're paid. If the title shows a lender, your storage lien is capped at $500, though you can also claim what's left after the lender is paid. With no lender on the title, the cap is the car's value.

"Keeper of vehicles" includes garage keepers, self-storage facilities and tow operators.

Shop

“Every keeper of vehicles shall have a lien upon such vehicles for the amount that may be due him for the towing, storage, recovery, and care thereof, until such amount is paid.”

Va. Code § 46.2-644.01
Shop

“In the case of any vehicle for which the title shows an existing lien, the keeper of vehicles shall have a lien upon the vehicle for his reasonable charges for storage under this section not to exceed $500; however, the keeper of vehicles shall also be entitled to a lien against any proceeds remaining after the satisfaction of all prior security interests or liens.”

Va. Code § 46.2-644.01
Shop

“In the case of any vehicle not subject to an existing lien on the title, the keeper of vehicles shall have a lien thereon for his reasonable charges for storage under this section, alone or in combination with a lien under § 46.2-644.02 not to exceed the value of the vehicle as determined by the provisions of § 8.01-419.1.”

Va. Code § 46.2-644.01
Insurer

“G. An insurer shall provide reasonable notice to a claimant prior to termination of payment for automobile storage charges. The insurer shall provide reasonable time for the claimant to remove the automobile from storage prior to the termination of payment.”

14VAC5-400-80, effective 1/1/2018
WashingtonAll Washington rulesSince October 18, 2026, before the insurer stops paying storage it must tell the claimant by phone or in writing, note it in the claim file, and allow reasonable time to move the car: 5 calendar days unless the claimant agrees to less. We found no storage-charge rule for body shops in our Washington collection. The towing fee rules in our collection bind registered tow truck operators, who can charge only fees filed with the state, figured per 24 hours to the nearest half day.

The two shop-side rows bind registered tow truck operators. We found no storage-charge rule for body shops in our Washington collection. The insurer rule shown is effective October 18, 2026.

Insurer

“(1) Advise the claimant by phone or in writing before it stops payment for storage of the loss vehicle. This communication must be documented in the claim file.”

WAC 284-30-394, effective 10/18/2026
Insurer

“(2) Provide reasonable time for the claimant to move the loss vehicle before stopping payment for storage. Five calendar days is considered reasonable time unless the claimant agrees to a shorter time period”

WAC 284-30-394, effective 10/18/2026
Tow and storage lot

“An operator shall file a fee schedule with the department. All filed fees must be adequate to cover the costs of service provided. No fees may exceed those filed with the department.”

RCW 46.55.063
Tow and storage lot

“Fees that are charged for the storage of a vehicle, or for other items of personal property registered or titled with the department, must be calculated on a twenty-four hour basis and must be charged to the nearest half day from the time when the operator has unloaded the vehicle and completed the necessary paperwork at the secure storage area.”

RCW 46.55.063

Where these quotes come from

Each quote is copied from the official text published by the state's legislature or agencies, which Collision CoPilot captures and monitors for changes. Where a row says otherwise, as with two New Jersey rules read from Cornell LII's copy, the note says so. Each citation links to its source and shows the edition or effective date of the text. This page was last checked on October 23, 2026.

Indiana Code text was retrieved through the Indiana General Assembly's Public API in October 2026. INscribe and the Indiana General Assembly cannot vouch for the data or analyses derived from these data after the data have been retrieved from INscribe.

What this page is not

This page quotes the law. It does not apply it to a particular vehicle, policy or invoice, and it is not legal advice. BainbridgeAI LLC is not a law firm. Local ordinances, court decisions and the wording of the policy can change how a rule applies. If the text does not settle your question, take it to a licensed attorney in your state.

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