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Digital-asset custody questions for Hawaii businesses

Hawaii’s Digital Currency Innovation Lab ended on June 30, 2024. The state DFI says digital-currency companies may continue without a Hawaii money-transmitter license under that program, leaving a buyer to verify the actual business entity, custodian and customer-asset contract rather than treating a state license as proof of protection. 1,2

What Is Digital Assets?

Digital-asset coverage may address custody, theft and business-liability risks, but a custodian’s policy may protect the custodian rather than you. If you hold or safeguard assets, verify the insured entity, wallets, key-loss protection and valuation. Read the national Digital assets guide.

What to Watch for in Hawaii

  • Do not use the old pilot as a current license signal

    The DCIL program ended June 30, 2024. DFI’s post-program statement is limited to state money-transmitter licensing under that program and does not resolve every other state or federal requirement. 1

  • A state program did not guarantee customer balances

    DFI warned that virtual-currency transactions were not government-guaranteed and that access or company failure could result in loss. That warning describes risk; it does not establish insurance availability. 2

  • A custodian’s policy may insure the custodian

    A provider’s insurance page may name the provider itself as insured and limit eligibility by entity or location. Ask how your customer claim would be treated rather than relying on a general statement that the custodian is insured. 3

Who Regulates Insurance in Hawaii

Hawaiʻi Insurance Division

The Insurance Division oversees insurance companies and producers, examines Hawaiʻi-based insurers, reviews rate and policy filings, and investigates insurance complaints. It is part of the Department of Commerce and Consumer Affairs. 5,6,7

Surplus-lines tax and stamping office

Reported tax rate: 4.68% of premium when Hawaiʻi is the home state Hawaiʻi applies a 4.68% tax when it is the insured’s home state. Surplus-lines coverage is placed with an unauthorized insurer, so do not assume the Hawaiʻi Insurance Guaranty Association protects the policy; confirm the insurer’s status and policy terms with your broker. 8,9

Providers With Documented State Licenses

No provider in Spot’s research documents both a state license record and this coverage line. This does not establish that providers are unlicensed. Check the regulator’s license lookup and confirm availability with a provider when requesting a quote.

Questions to Ask Before You Buy in Hawaii

  1. Who holds the assets for your Hawaii customers today, and which legal entity is party to the custody agreement?
  2. Does your policy or the custodian’s policy identify the assets, wallets, key holders and customers whose loss may be addressed?
  3. For a loss of access, outside theft or employee misuse, which cause of loss is actually within the policy wording?
  4. How are customer claims handled if the custodian, platform or an affiliate fails or changes its service?

Digital Assets in Hawaii: FAQ

Does the ended Hawaii pilot prove that a digital-currency company is insured? 1,2

No. DFI says companies no longer need a state money-transmitter license under the former DCIL program. That is a licensing statement, not an insurance or customer-recovery guarantee. 1,2

Does Hawaii make digital-asset coverage unavailable? 1,3,4

The cited DFI materials do not establish that coverage is unavailable. Ask the broker and insurer to identify the insured entity, covered assets, key arrangement and applicable exclusions. 1,3,4

Digital Assets in Other States

Other Coverage in Hawaii

Sources

  1. Hawaii Digital Currency Innovation Lab Concludes; Public Reminded to Be Aware of Risks. Hawaii Department of Commerce and Consumer Affairs, Division of Financial Institutions; Release published June 28, 2024, updated April 27, 2026; post-DCIL licensing status effective after June 30, 2024. Accessed 2026-09-28.
  2. Digital Currency Innovation Lab Frequently Asked Questions for Consumers. Hawaii DFI; FAQ marked 02.09.24; post-program regulatory status, company/access loss and no government guarantee. Accessed 2026-09-28.
  3. Insurance. BitGo; Current page: custody and key-control description; direct-insured entity and location/entity eligibility qualifiers. Accessed 2026-09-28.
  4. Performance Management — Supplemental Requirements & Guidance. Lloyd’s; January 2020, pp.44–46: historic underwriting considerations for key security, hot/cold storage, code/network risk, insured identity and valuation; historical market guidance only. Accessed 2026-09-28.
  5. Insurance Division. Hawaiʻi Department of Commerce and Consumer Affairs; Official division homepage; scope, license search, complaints, contact information. Accessed 2026-09-28.
  6. Insurance Licenses and Registrations. Hawaiʻi Insurance Division; Insurance license information; links to state-based system for license applications and status. Accessed 2026-09-28.
  7. Filing a Complaint. Hawaiʻi Insurance Division; Online complaint form and published consumer phone. Accessed 2026-09-28.
  8. Surplus Lines Tax. Hawaiʻi Insurance Division; 4.68% rate and home-state application under HRS § 431:8-315. Accessed 2026-09-28.
  9. HRS § 431:16-105: Definitions. Hawaiʻi Legislature; Defines a member insurer as an insurer licensed or holding a certificate of authority in Hawaiʻi; cross-read with HRS § 431:8-102 and § 431:8-301 for unauthorized surplus-lines placements. Accessed 2026-09-28.
  10. Licenses. At-Bay; Current producer introduction and state table; At-Bay Insurance Services LLC; P&C and surplus-lines identifiers. Accessed 2026-09-21.
  11. Licenses and Carriers. Coalition; Licenses and Carriers, re-read 22 September 2026: Insurance Licenses table for Coalition Insurance Solutions, Inc., national producer number 18419475, with producer and surplus-lines numbers for all 50 states and DC including California 0L76155, Georgia 196479, Texas 2199630 and 2205589, Pennsylvania 815731 and 817452, Colorado 539028 and Wisconsin 3000108852. Insurance Carriers table naming, with NAIC numbers, Allianz Underwriters Insurance Company 36420, Arch Specialty Insurance Company 21199, Ascot Specialty Insurance Company 45055, Ascot Insurance Company 23752, Aspen Specialty Insurance Company 10717, Chaucer Insurance Company DAC, Coalition Insurance Company 29530, Fireman's Fund Indemnity Corporation 11380, Fortegra Specialty Insurance Company 16823, Lloyd's of London, MSIG Specialty Insurance USA Inc. 34886, MS Transverse Specialty Insurance Company 41807, Steadfast Insurance Company 26387, Vantage Risk Specialty Insurance Company 16275 and Zurich American Insurance Company 16535. Accessed 2026-09-22.
  12. Insurance Producer Licenses. Corgi Insurance; Current complete Insurance Producer Licenses table for Corgi Insurance Services, Inc.; 50 rows covering 49 states and DC (DC 3003091619); no New Mexico row; no NPN or as-of date shown. Accessed 2026-09-28.
  13. About Hiscox US Insurance. Hiscox; Hiscox Insurance Company Inc. NAIC 10200 as Chicago, IL domiciled insurer admitted or licensed in all 50 states and D.C.; Hiscox Inc. as general agent and Lloyd’s coverholder for Syndicates 33 and 3624; surplus-lines placements through licensed surplus-lines brokers; A.M. Best rating statement. Accessed 2026-09-16.
  14. Licenses. ERGO NEXT Insurance; Current entity-by-state license table reopened 28 September 2026: 50 rows under Next First Insurance Agency, Inc., including Washington, DC; New York rows instead list Next Insurance Services PC-1423070 and AP Intego BR-1198885. Accessed 2026-09-28.
  15. Insurance Licenses by State. TechInsurance; Current state table; identifies TechInsurance as a division of Specialty Program Group LLC d/b/a SPG Insurance Solutions; lists DC 3000041536 and labels Rhode Island “Individual licenses,” without an agency license number. Accessed 2026-09-28.
  16. Licenses. Vouch; Effective 16 January 2025: Vouch Specialty Insurance Services, LLC, NPN 19926463; P&C table (50 states and DC); surplus-lines table includes Idaho 870820; footnote says Georgia and Idaho do not issue agency-level surplus-lines licenses; Idaho retained as producer-only due to conflict. Accessed 2026-09-15.

Updated .

This guide is informational and does not determine whether a policy is available or meets your needs. Editorial policy. To suggest a correction, contact Spot with a supporting source.

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