CE Exemptions in Virginia: Who Qualifies for the 65/20 Grandfather Rule

Virginia has a CE exemption for long-tenured senior producers — the 65/20 rule — but the exemption is not automatic, is subject to strict continuity requirements, and was significantly changed by legislation effective January 1, 2019. Producers who qualified for the permanent exemption before December 31, 2018 were grandfathered; new exemptions under the old rule are no longer available. The current CE exemption framework has two qualifying paths, both of which require age and continuous licensure, and both of which are voided permanently if the producer allows their license to lapse. This post explains who qualifies, what the exemption provides, and what threatens it.

The 65/20 Rule: Two Qualifying Paths

Virginia currently recognizes two versions of the 65/20 CE exemption:

Path 1 — Grandfathered permanent exemption (pre-2019): Producers who received a permanent CE exemption by December 31, 2018 based on being age 65 or older with 20 or more consecutive years of Virginia licensure retain that exemption on a grandfathered basis. This exemption is permanent as long as:

The producer continues to renew their license on time

The license is never allowed to lapse

The producer does not fail to renew within 12 months of the renewal date

Path 2 — Current ongoing exemption (two qualifying criteria):

Criterion A: A resident producer who is at least 65 years old and can demonstrate they have held any combination of resident or nonresident Virginia licenses of equivalent type continuously for at least 20 years is exempt from CE requirements.

Criterion B: A resident producer who is at least 65 years old and has held a Virginia resident license continuously for the preceding 4 years and can furnish proof of having held equivalent license authority continuously in other states for an additional 16 years (totaling 20 years of continuous licensing in any combination) is also exempt.

Both paths require continuous licensure — no gaps. A single lapse in licensure eliminates the exemption and cannot be recovered.

What the Exemption Provides

Producers who qualify for the CE exemption under either path are exempt from completing CE hours as a condition of license renewal. They must still:

Submit a renewal application through NIPR or Sircon by their renewal deadline (end of birth month in their odd/even year)

Pay the $10 per-line renewal fee

Pay the CE continuance fee if applicable (confirm current requirements with Pearson VUE)

The CE exemption eliminates the 16 or 24-hour CE obligation. It does not eliminate the renewal fee or the renewal application requirement.

The 2019 Change: What It Means for New Exemption Claims

The Virginia General Assembly repealed the availability of new 65/20 permanent exemptions effective January 1, 2019. A producer who turns 65 with 20 years of continuous licensure after December 31, 2018 is still eligible for an ongoing CE exemption under the current rule — but the exemption is evaluated on an ongoing basis at each renewal rather than granted permanently in advance. This is a subtle but meaningful difference from the pre-2019 permanent grant.

Practically: Producers who currently qualify at age 65+ with 20 years of continuous licensure can claim the exemption at renewal. However, any future lapse in licensure permanently voids the exemption, and the producer cannot re-qualify.

How Licensure Continuity is Measured

"Continuously" means without any gap in licensure. The 20 years of continuous licensure can be counted across:

Virginia resident licenses

Virginia nonresident licenses (for Path 1/Criterion A, using equivalent license types)

Licenses held in other states (for Path 2/Criterion B, up to 16 of the 20 years)

A producer who held a Life & Annuities license in Maryland for 16 years, then relocated to Virginia and has held a Virginia resident Life & Annuities license for 4 consecutive years, meets Criterion B if they are at least 65 years old at the time of the renewal period.

Specialty Training Requirements: Not Exempt

CE exemption does not eliminate specialty training obligations. A producer who qualifies for the 65/20 CE exemption and sells LTC Partnership policies must still complete the initial 8-hour LTC Partnership training and the ongoing 4-hour training every 24 months. The annuity best interest one-time training and the one-time NFIP flood training similarly apply to exempt producers who sell those products. The CE exemption covers only the general biennial CE hour requirement — specialty product training requirements are separate obligations rooted in product authorization, not CE compliance.

Limited Lines License Holders

Virginia producers who hold only limited lines licenses (credit life/health, travel accident, travel baggage insurance) are also exempt from CE requirements. Limited lines are narrow product authorizations that do not require CE compliance under Virginia's current framework.

Frequently Asked Questions

If I received a permanent CE exemption before 2019 and my license recently lapsed, can I reinstate and reclaim the exemption?

No. Virginia's CE exemption rules — for both grandfathered permanent exemptions and current ongoing exemptions — specify that the exemption is void if the license lapses and is not reinstated within 12 months of the renewal date. If a grandfathered producer fails to renew on time and allows the license to terminate past the 12-month reinstatement window, the permanent exemption is permanently lost. Even within the 12-month reinstatement window, allowing a license to lapse is a risk to the exemption's continuity — confirm with the Bureau of Insurance at AgentLicensing@scc.virginia.gov before attempting reinstatement if the exemption was previously in place.

Does the CE exemption apply to non-resident Virginia license holders?

Non-resident producers are generally not required to complete Virginia CE regardless of age or tenure — Virginia accepts CE compliance from the producer's home state for non-resident license holders. The 65/20 exemption is specifically a resident producer exemption. Non-resident producers do not need to claim or qualify for the 65/20 exemption because the non-resident CE waiver applies across the board. The relevant non-resident CE obligation is compliance with their home state's CE requirements.

How do I claim the CE exemption when renewing my Virginia insurance license?

CE exemption claims are typically made as part of the license renewal process through NIPR or Sircon. The renewal application includes fields for certifying CE compliance or claiming an exemption. Producers claiming the exemption should be prepared to document the basis for the exemption — age (65+) and continuous licensure documentation — if the Bureau requests verification. For producers claiming Path 2/Criterion B (combining Virginia and out-of-state continuous licensure to reach 20 years), documentation of out-of-state licensure history may be required. Contact the Bureau of Insurance at BOILicenseRenewal@scc.virginia.gov for specific documentation requirements before claiming the exemption for the first time.

Can a producer who qualifies for the CE exemption choose to take CE courses anyway?

Yes. CE exemption is voluntary — it is a permission, not a prohibition. An exempt producer who wants to stay current with industry changes, complete specialty training, or maintain professional development can take CE courses and have them credited to their record. For exempt producers who complete CE courses, the CE continuance fee must still be paid to have those credits applied to the record, even if the credits are not required for renewal. Excess credits from voluntary CE do not carry forward meaningfully for an exempt producer, but the educational value and the regulatory currency the courses provide are independent of the exemption status.

Does the 65/20 CE exemption apply to the continuance fee obligation?

This is a nuanced point — the CE continuance fee is administered by Pearson VUE separately from the Bureau of Insurance renewal process. Confirm directly with Pearson VUE (877-234-6093 or VirginiaInsuranceCE@pearson.com) whether exempt producers are required to pay the continuance fee when no CE is completed. The general principle is that the continuance fee is associated with the CE program administration and may apply differently for exempt versus compliant producers. Do not assume the continuance fee is waived for exempt producers without specific confirmation from the CE administrator.

The 65/20 CE exemption is a meaningful benefit for Virginia's longest-tenured senior producers, but it requires careful maintenance — continuous licensure, timely renewal, and ongoing specialty training compliance for applicable products. A single lapse permanently voids an exemption that may represent decades of earned tenure.

Visit JustInsurance to enroll today and stay compliant with all Virginia CE and specialty training requirements with state-approved courses.