HB2175 creates a new statutory framework in Tennessee for delivery network companies and their drivers, focused primarily on insurance, disclosure, and liability rules. The bill defines key terms such as “delivery network company,” “delivery driver,” “delivery availability period,” and “delivery service period,” and distinguishes delivery-network activity from for-hire vehicle and street-hail services. It also specifies that a delivery network company is not generally deemed to control or manage drivers’ personal vehicles, except where a written contract says otherwise.
The bill requires, beginning July 1, 2026, that either the driver, the delivery network company, or both maintain automobile liability coverage during the relevant delivery periods. The required minimum coverage is $50,000 for bodily injury to one person, $100,000 for bodily injury to all persons in an accident, and $25,000 for property damage. If a driver’s coverage lapses or is insufficient, the company’s insurance must step in as primary coverage from the first dollar and include a duty to defend. The bill also allows insurers to exclude coverage for losses occurring during delivery activity, sets rules for claims investigations and information-sharing, and requires delivery network companies to disclose coverage information and warn drivers that their personal auto policy may not cover delivery activity.
In addition to amending the motor vehicle and insurance titles, the bill states that the required coverage satisfies Tennessee’s Financial Responsibility Law while the driver is logged into the platform or actively delivering, but not when the driver is off-platform. It also authorizes insurers to exclude delivery-related losses from various coverages, including liability, uninsured/underinsured motorist, medical payments, comprehensive, and collision coverage, and preserves existing underwriting, cancellation, and nonrenewal authority. The act takes effect January 1, 2027.
The overall sentiment appears generally favorable, with strong support in committee and on the House floor, though not unanimous. The bill advanced 8-0 in the House Business and Utilities Subcommittee, 13-1 in the House Commerce Committee, and 88-4 on third consideration in the House, suggesting broad agreement on the need to regulate delivery-platform insurance coverage. The later 19-9 third-consideration vote indicates some continued opposition or concern, but the measure ultimately passed and was enacted.
The main points of contention appear to center on how much risk should be shifted to delivery network companies and insurers, and how broadly insurers may exclude coverage for delivery-related activity. The bill’s provisions requiring companies to provide primary coverage when a driver’s policy is unavailable, along with the duty to defend and the rule that the company’s coverage is not contingent on another insurer first denying a claim, likely reflect efforts to address coverage gaps. At the same time, the express permission for insurers to exclude delivery-period losses and the statement that DNCs are not deemed to control drivers or vehicles may have raised concerns among some lawmakers, insurers, or stakeholders about liability allocation and worker classification.
HB2175 amends Tennessee law in Titles 55, 56, and 65 to create a specific insurance and disclosure regime for delivery network companies and their drivers. It establishes statutory definitions and rules governing when coverage applies, what minimum automobile liability limits are required, how claims are handled, and what disclosures must be made to drivers. The bill also clarifies that delivery-network coverage can satisfy the state financial responsibility law during logged-in or delivery periods, while preserving ordinary auto insurance requirements when the driver is not engaged in delivery work.
The bill appears to have received generally positive treatment in the legislative process, with unanimous or near-unanimous committee support and strong floor passage. The vote history suggests broad acceptance of the need to address insurance coverage for app-based delivery work, though the non-unanimous final votes indicate some legislators had reservations. Overall, the sentiment was favorable but not without some concern about the bill’s liability and insurance implications.
The likely areas of disagreement were the allocation of insurance responsibility between drivers, delivery network companies, and insurers, and the extent to which insurers may exclude delivery-related losses. Some stakeholders may have favored stronger consumer and driver protections, while others may have been concerned about increased costs, expanded liability, or the effect on existing auto policy exclusions. The bill’s explicit statement that DNCs are not deemed to control drivers or vehicles also suggests sensitivity to broader questions about platform responsibility and possible worker-classification implications.