Tennessee vs. Kentucky vs. Virginia: How CE Requirements Compare

Tennessee, Kentucky, and Virginia share both geography and significant producer overlap along the Appalachian corridor — producers based near state lines routinely hold licenses in two or three of these states simultaneously, and producers considering multi-state practice face a genuine comparison question about ongoing CE obligations. All three states use biennial birth month renewal cycles and require ethics CE. But the total hours required, whether those hours must be line-specific, how carryover works, what specialty training is required for specific products, and how non-residents are treated differ meaningfully across the three states. This post provides the complete current comparison across every CE dimension that affects a working producer's ongoing compliance planning.

The Total Hours Comparison

The headline CE requirement — total hours per biennial period — produces one of the most significant structural differences across the three states.

Tennessee: 24 hours per biennial period regardless of how many lines the producer holds. A Tennessee producer with all four major lines completes the same 24 hours as a producer with only one line.

Kentucky: 24 hours per biennial period regardless of how many lines the producer holds. Same headline number as Tennessee — but with a line-specific distribution requirement discussed below.

Virginia: The total hours depend on how many license types the producer holds.

Single license (or Life, Annuities, and Health together — which Virginia counts as one license): 16 hours

Two or more license types: 24 hours

Virginia's tiered structure is the most distinctive feature of the three-state comparison. A Virginia producer holding only a Life and Health license completes 16 CE hours — 8 fewer than their Tennessee or Kentucky counterparts. A Virginia producer holding Property and Casualty plus Life and Health completes 24 hours — matching the other two states. This means Virginia single-license producers have a meaningfully lower CE burden than either Tennessee or Kentucky producers.

Virginia's "single license" definition: Life, Annuities, and Health is counted as a single license for Virginia CE purposes. A producer who holds Life and Health lines — but not Property or Casualty — is a single-license holder with a 16-hour requirement. The moment they add a Property or Casualty license, they become a multi-license holder with a 24-hour requirement and the minimum-per-line distribution requirement.

Ethics Requirements

All three states require ethics CE as part of the biennial total. The specific hour requirement is the same across all three:

The ethics requirement is identical in number. The differences are in what qualifies as ethics CE in each state.

Tennessee: Ethics CE must be content specifically approved by the TDCI as ethics content. Insurance law and regulation courses do not automatically satisfy the ethics requirement — the course must carry an explicit TDCI ethics designation.

Kentucky: Ethics CE must be from courses specifically approved for ethics credit. The same designation requirement applies — content relevance alone does not satisfy the ethics requirement without the state's ethics designation on the specific course.

Virginia: Ethics CE may include Virginia Insurance Laws and Regulations content — a broader definition than Tennessee's or Kentucky's. A course on Virginia insurance law that carries the ethics credit designation satisfies Virginia's 3-hour ethics requirement. This makes Virginia's ethics requirement somewhat more flexible in terms of qualifying content than the other two states.

Carryover of excess ethics hours: All three states restrict the carryover of excess ethics hours. Excess ethics hours carry as general CE credit in the next period — not as ethics credit. A producer who completes 6 ethics hours in a period has 3 credited as ethics and 3 as general. The next period's 3-hour ethics requirement must be satisfied with newly designated ethics CE.

Line-Specific Distribution Requirements

This is one of the most consequential structural differences across the three states and the provision most frequently missed by producers managing multi-state CE.

Tennessee: No line-type restriction. Tennessee CE is entirely non-line-specific. A Tennessee producer holding Property and Casualty can complete all 24 CE hours in life insurance courses and satisfy the full CE requirement for both Property and Casualty. Course subject matter can be anything in any insurance line — as long as it is TDCI-approved.

Kentucky: At least 6 of the 24 required CE hours must be completed in a line of authority for which the producer is actively licensed. The remaining 18 hours may be in any subject matter. A Kentucky P&C producer must complete at least 6 hours specifically relevant to their P&C line. A Kentucky producer holding both P&C and Life/Health still needs only 6 total hours in a held line — not 6 per line.

Virginia: The most restrictive line-specific requirement of the three states.

Single-license producers (16 hours): All 16 hours must be relevant to the license type held

Multi-license producers (24 hours): At least 8 hours must be completed in each license type held

For Virginia multi-license producers, the 8-hours-per-license-type requirement means that a producer holding Property and Casualty plus Life and Health must complete at least 8 hours specifically in P&C content and at least 8 hours specifically in Life/Health content. The remaining 8 hours may be in any approved subject matter. Other General Insurance (OGI) credits can be used to meet any license-specific requirement but will not meet the ethics requirement.

The practical impact of Virginia's line distribution rule: A Virginia multi-license producer cannot satisfy their CE requirement entirely through courses in one subject area — even if the total hours are correct. A Virginia P&C and Life/Health producer who completes 20 hours of life insurance courses and 4 hours of P&C courses has not satisfied the requirement — they need at least 8 hours in each license type. This constraint requires deliberate CE planning in Virginia that Tennessee and Kentucky producers do not face.

Company-Sponsored CE Limits

Tennessee: No confirmed mandatory cap on company-sponsored CE hours under current TDCI rules. Tennessee does not impose the same structured company-sponsored percentage limit as some states.

Kentucky: No confirmed rigid company-sponsored CE cap analogous to states like Minnesota's 50% limit. Kentucky's rules do not prominently feature a company-sponsored hour restriction in the same structural way.

Virginia: No more than 75% of required CE credits may come from courses provided or given by insurance agencies or insurance companies. For a 16-hour requirement, a maximum of 12 hours can be company-sponsored. For a 24-hour requirement, a maximum of 18 hours can be company-sponsored. Virginia's 75% cap is the most explicitly defined company-sponsored limit of the three states.

Additionally effective February 1, 2026, Virginia limits producers to no more than 12 CE hours of content completed within any consecutive 24-hour period. This new rule prevents producers from completing their entire CE requirement in a single intensive session.

CE Carryover

All three states allow carryover of excess CE hours to the next biennial period — a feature that Tennessee, which did not historically permit carryover, now provides.

Tennessee and Kentucky carryover: Both states allow up to 12 hours of excess CE to carry forward as general credit. Excess ethics hours carry as general CE — not as ethics credit in the next period. The 12-hour maximum applies regardless of how many excess hours were completed.

Virginia carryover: Virginia allows carryover of excess hours, with the specific rule that hours must be reported in the biennium in which the course was taken. Virginia also allows excess ethics credits to be applied to cover other CE requirements in the current renewal period — and any remaining excess will carry forward into the next period where they can be applied to either ethics or other CE requirements. This is somewhat more flexible than Tennessee's and Kentucky's handling of excess ethics hours.

Renewal Deadlines and Fee Structure

All three states use the same renewal deadline structure: last day of the birth month, biennially, with the odd/even year determined by the producer's birth year.

Tennessee provides the most producer-friendly late renewal structure — a 30-day grace period with no additional fee, followed by up to one full year from expiration for late renewal at a $120 late fee.

Kentucky allows late renewals for up to two months. The structure is more limited than Tennessee's one-year window — Kentucky producers who miss renewal by more than two months face full relicensing requirements more quickly than Tennessee producers.

Virginia has a specific annual continuance fee requirement. Virginia resident agents must pay a biennial nonrefundable continuance fee — due by November 30 — before any earned CE credits are applied to the CE requirements. This is a Virginia-specific administrative step that neither Tennessee nor Kentucky requires. Virginia producers who are unaware of this fee may find their CE credits are not applied to their record until the fee is paid.

Virginia also has a CE reporting fee: $2.60 per credit hour reported. This per-hour reporting fee — charged to the producer — is unique among the three states. Tennessee and Kentucky do not charge per-hour reporting fees. Virginia producers completing 24 CE hours pay $62.40 in reporting fees ($2.60 × 24) in addition to their renewal continuance fee.

Specialty Training Comparison

All three states require specialty product training following NAIC model frameworks. The training structures are largely parallel but have state-specific variations.

Virginia's LTC training distinction: Virginia has the most demanding LTC training requirement of the three states. The initial 8-hour training must include 6 hours of general LTC content and 2 hours of Virginia-specific LTC Partnership content. The ongoing 4-hour training must include 2 hours of Virginia-specific content. This Virginia-specific content requirement means that non-residents selling LTC in Virginia must complete both an NAIC-approved 8-hour course and a separate 2-hour Virginia LTC Partnership course — they cannot satisfy Virginia's requirement solely through out-of-state NAIC training.

Non-Resident CE Treatment

All three states exempt non-resident producers from their CE requirements when home state CE is current — following the standard NAIC Producer Licensing Model Act reciprocity framework.

Tennessee: Non-resident producers whose home state CE is current are fully exempt from Tennessee CE requirements. The LTC training exception applies — non-residents selling LTC in Tennessee must complete LTC training, though NAIC model-based training from other states is recognized.

Kentucky: Non-resident producers are exempt from Kentucky CE requirements when their home state CE is current. Non-resident adjusters who are licensed and in good standing in their resident state are exempt.

Virginia: Non-resident producers are exempt from Virginia CE requirements based on reciprocity. However, non-residents selling LTC in Virginia face the most demanding non-resident LTC requirement of the three states — they must complete the 8-hour NAIC LTC course and the 2-hour Virginia LTC Partnership course, even though they are otherwise exempt from Virginia CE.

The Master Comparison Table

Who Benefits Most From Each State's Structure

Tennessee benefits producers who: Want maximum CE subject matter flexibility with no line-type restrictions, who want the longest late renewal window (one year), who prefer no per-hour reporting fees, and who value the absence of an annual continuance fee obligation.

Kentucky benefits producers who: Hold licenses in multiple lines but want a relatively light line-type restriction (only 6 hours in a held line), who complete CE in line-specific content naturally through their practice, and who value carryover with the same 12-hour maximum as Tennessee.

Virginia benefits producers who: Hold only a single license type — the 16-hour requirement is the lowest of the three states for single-license holders. The savings of 8 hours per biennial period for single-license holders is meaningful over a career. However, Virginia's per-hour reporting fee, annual continuance fee, line-type restriction for multi-license holders, and Virginia-specific LTC content requirements add administrative and financial burden that partially offset the hours advantage.

Frequently Asked Questions

I am a Tennessee resident producer holding Property and Casualty. I want to add a Virginia non-resident license. What CE obligations does the Virginia license create?

As a non-resident producer from Tennessee, you are exempt from Virginia's CE requirements when your Tennessee CE is current. You do not need to complete any Virginia-specific CE courses, satisfy Virginia's line-type distribution requirement, or pay Virginia's per-hour reporting fee for CE courses. Your Tennessee 24-hour biennial CE — completed through TDCI-approved courses — simultaneously satisfies your Virginia non-resident CE obligation. The one area requiring additional attention is if you sell LTC products in Virginia — Virginia's non-resident LTC training requirement mandates an 8-hour NAIC LTC course plus a 2-hour Virginia LTC Partnership course even for non-residents, which exceeds what most other states require of non-residents. Confirm with the Virginia Bureau of Insurance whether your Tennessee LTC training completion satisfies the NAIC component of Virginia's requirement, and plan for the Virginia-specific 2-hour LTC Partnership course if you intend to sell LTC products in Virginia.

A Kentucky producer with Property and Casualty plus Life and Health asks: can I complete all 24 CE hours in life insurance topics and satisfy the Kentucky requirement?

No — not fully. Kentucky requires at least 6 of the 24 CE hours to be completed in a line of authority for which you are actively licensed. With both P&C and Life/Health licenses, you must complete at least 6 hours in either P&C or Life/Health subject matter. The remaining 18 hours may be in any approved subject matter including life insurance topics if that is your preference. The 6-hour line-specific minimum is the binding constraint — as long as you satisfy it, the remaining hours have no subject matter restriction. The easiest compliance path: complete at least 6 hours of P&C or Life/Health content, 3 hours of ethics-designated content, and fill the remaining 15 hours with any TDCI or Kentucky DOI-approved courses in whatever subject matter you prefer.

Virginia's 8-hours-per-license-type requirement sounds complex for multi-license producers. How does a Virginia producer with three license types calculate their CE distribution?

Virginia multi-license producers with three license types still face a 24-hour total CE requirement — not 8 × 3 = 24 hours separately per line. The rule requires at least 8 hours applicable to each license type held, but those hours can overlap when a course covers multiple license types — and the 24-hour total is the ceiling, not multiplied by license count. However, Virginia's guidance establishes that Life, Annuities, and Health is counted as a single license for CE purposes. If your three licenses are Property, Casualty, and Life/Health, Virginia may count Property and Casualty as separate license types requiring 8 hours each — which would mean at least 8 hours of P&C content, at least 8 hours of Life/Health content, and the 3 ethics hours within the 24-hour total. The remaining hours fill the balance in any approved subject matter. Contact the Virginia Bureau of Insurance directly at the State Corporation Commission to confirm how your specific combination of licenses is classified for the 8-hours-per-type rule before planning your Virginia CE strategy.

Tennessee, Kentucky, and Virginia each approach continuing education from a distinct framework — the same Appalachian regional geography producing three meaningfully different ongoing compliance structures. Tennessee offers the most flexible CE subject matter approach with no line restrictions and the longest late renewal window. Kentucky adds a modest 6-hour line-specific requirement while otherwise matching Tennessee's flexibility. Virginia offers single-license holders the lowest total hour requirement in the region but imposes the most structured line-type distribution, the only per-hour reporting fee, an annual continuance fee, and the most demanding non-resident LTC training obligation. Producers who understand these differences manage multi-state CE efficiently — taking advantage of Tennessee's flexibility for general CE while planning Virginia-specific and Kentucky-specific line requirements deliberately to avoid the compliance gaps that arise when producers assume all three states work the same way.

Visit JustInsurance to enroll today and complete your Tennessee CE requirements with a state-approved provider — the foundation of multi-state CE compliance that starts with your resident state.