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50-STATE REGULATORY KNOWLEDGE BASE • UPDATED FOR 2026

50-State Seller of Travel Laws & Licensing Directory

The definitive legal guide for independent travel advisors. Understand the registration rules, surety bond thresholds, and statutory host agency exemptions across California, Florida, Washington, Hawaii, Iowa, and the 45 non-SOT states.

View Regulated States Matrix Search 50 States →

SOT Compliance at a Glance

Quick facts every independent advisor must know:

• 5 Regulated States:
CA, FL, WA, HI, IA require direct registration or statutory host exemption.
• 45 Non-SOT States:
No state travel license required; standard general business LLC rules apply.
• Host Exemption Power:
Partnering with a compliant host saves you $5,000+ in annual bonds and filing fees.
Interactive Diagnostic

30-Second SOT Compliance Diagnostic Tool

Select your business location and operating model to instantly see your licensing requirements, surety bond thresholds, and statutory exemption options.

Compliant Pathway Identified

General Business Rules Apply

Your business is located in a non-SOT state. You do not need a state travel agency license to operate.

Licensing / Filing Fees:
$0 state license fee. Standard home-state LLC fees apply.
Surety Bond / Trust Account:
No state bond required. Commercial E&O insurance recommended ($350/yr).
Core Comparison

The 5 Regulated Seller of Travel States: Cost & Requirement Matrix

If your business is based in one of these five states — or if you actively advertise and sell travel to residents in these states — you are legally subject to their consumer protection statutes:

State & Statute Governing Agency Annual Registration Fee Financial Security / Bond Host Agency IC Exemption
CA California
Cal. Bus. & Prof. § 17550 		CA Attorney General (DOJ) $100 / location + $275 TCRC fund $100,000 Surety Bond OR dedicated Trust Account YES § 17550.20(e)
Must use host’s CST# & accounts
FL Florida
FL Statute § 559.927 		FDACS (Dept of Agriculture) $300 annual filing fee $10,000 to $50,000 Surety Bond YES Form FDACS-10211
$50 annual exemption fee
WA Washington
RCW Chapter 19.138 		WA Dept of Licensing $202 + $25 per branch Client Trust Account OR Surety Bond YES (RCW 19.138.100)
Independent contractor exemption
HI Hawaii
HRS Chapter 468L 		DCCA (Dept of Commerce) $215 biennium ($140 renewal) Mandatory Hawaii-based Client Trust Account RESTRICTED
Requires strict escrow / host trust
IA Iowa
Iowa Code Chapter 9D 		Iowa Secretary of State $15 annual filing fee None required by statute NOT NEEDED
Direct registration is only $15

California Seller of Travel Law (CST)

STRICT COMPLIANCE

California has the most rigorous consumer protection travel statute in the nation under California Business & Professions Code § 17550 et seq.

1. Direct Agency Registration Requirements

If you operate an independent agency in California without a host agency exemption, you must register with the California Attorney General’s Office. You must pay an initial $100 registration fee per location, an annual $275 assessment to the Travel Consumer Restitution Corporation (TCRC), and post a $100,000 surety bond or maintain an adequate trust account.

2. How to Claim the Independent Contractor Exemption (§ 17550.20(e))

Independent advisors can legally avoid the $100k bond and direct registration fees by qualifying as an Independent Contractor under a fully registered host agency. To qualify:

  • You must have a written contract with an active, compliant host agency possessing a valid CST number.
  • You must clearly display the host agency’s CST number and your business name on all websites, proposal decks, social media, and invoices.
  • All client credit card charges must be processed directly through suppliers or the host agency’s merchant account. You can never deposit client travel payments into your own personal bank account.

Florida Seller of Travel Law (ST Number)

STRICT COMPLIANCE

Administered by the Florida Department of Agriculture and Consumer Services (FDACS) under Florida Statutes § 559.926 – 559.939. Anyone offering travel services to persons in Florida must register.

1. The Independent Agent Exemption (FDACS Form 10211)

Direct agency registration in Florida costs $300 annually plus a $25,000 surety bond. However, Florida provides a streamlined exemption for independent contractors under FL Statute § 559.928(6):

  • File FDACS Form 10211 (Application for Independent Contractor Exemption).
  • Pay a nominal $50 annual filing fee (saving $250+).
  • Provide a signed affidavit verifying your host agency partnership.
  • Do not issue vacation certificates or take cash payments directly.

Washington, Hawaii, and Iowa Regulations

Washington State (RCW Chapter 19.138)

Regulated by the Washington Department of Licensing. Direct registration requires an application fee ($202) and maintenance of a client trust account in a federally insured Washington bank. Independent contractors working under a registered host are exempt provided all bookings are processed through the host.

Hawaii (HRS Chapter 468L)

Hawaii requires travel agencies and activity desks to maintain dedicated client trust accounts with Hawaii-based financial institutions. Out-of-state advisors marketing to Hawaii residents should partner with consortia and hosts that maintain active Hawaii registration.

Iowa (Iowa Code Chapter 9D)

Iowa operates the simplest SOT framework in the nation. Travel agencies simply submit a registration form and a $15 annual fee to the Iowa Secretary of State. No surety bond or host exemption form is required.

Operating in the 45 Non-SOT States

If your agency is located in any of the other 45 states (such as Texas, New York, Ohio, Illinois, Georgia, Pennsylvania, etc.), there is no specific travel agent occupational license required.

You simply register your standard LLC with your Secretary of State, obtain your IRS EIN, and carry Errors & Omissions insurance. However, always remember the golden rule of interstate consumer protection: if you market directly to clients residing in California or Florida, those states claim extraterritorial jurisdiction. Operating under an accredited host agency like Vincent Vacations automatically provides nationwide legal coverage.

Instant Download

E-Sign Chargeback Defense & SOT Legal Kit

Protect your agency from client disputes, bank chargebacks, and state regulatory audits with attorney-drafted templates.

  • Master Client Terms & Conditions Agreement
  • Credit Card Authorization & Fraud Defense Form
  • Florida FDACS Form 10211 Filing Guide
  • California CST Marketing Disclosure Templates
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Learn step-by-step how to navigate host accreditation, legal setup, and direct supplier access without surrendering 30% of your earnings.

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