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Pennsylvania EPLI: Four-person PHRA threshold and filing choice

Pennsylvania’s Human Relations Act generally includes employers with four or more people in the Commonwealth, but it excludes certain workers and distinguishes religious, fraternal, charitable, or sectarian entities by the protected basis and public funding. PHRC guidance says complaints generally must be filed within 180 days and describes a court option after agency filing. 1,2

What Is Employment Practices Liability?

EPLI can help pay covered defense costs and losses when applicants or workers allege discrimination, harassment, wrongful termination or other workplace wrongdoing. If you employ people, check the claim definition, defense costs and prior acts. Read the national Employment practices liability guide.

Pennsylvania Requirements

RequirementDetails
PHRA employer thresholdGenerally four or more persons within Pennsylvania; state and political subdivisions are included, with separate language for certain religious, fraternal, charitable, and sectarian entities. 1

What to Watch for in Pennsylvania

  • Entity type and claim basis affect scope

    PHRA §4(b) generally excludes religious, fraternal, charitable, or sectarian corporations and associations unless supported in whole or part by government appropriations, while naming several bases for which those entities employing four or more persons are included. Counsel should map entity status and protected basis before the business estimates exposure. 1

  • Some worker relationships are excluded

    The statute’s employee definition excludes agricultural workers, domestic service, some live-in workers, and employment by a parent, spouse, or child. The PHRC’s public guide summarizes the four-person company threshold but says there are other entity exceptions. Check the actual workforce relationship and insured-person wording. 1,2

  • The PHRC uses a short intake window

    Current PHRC guidance says that, in general, a complaint should be filed within 180 days. It also describes service on the respondent and a one-year point for seeking court action if the complaint remains unresolved or is dismissed. Ask whether the policy treats intake, service, or an agency investigation as a claim. 2

Who Regulates Insurance in Pennsylvania

Pennsylvania Insurance Department

The Pennsylvania Insurance Department publishes state tools to check licensed producers, agencies, and insurers, and its Consumer Services Online portal accepts complaints about insurers, agents, brokers, and public adjusters. The department also oversees Pennsylvania insurance business and consumer services. 3,4,5

Surplus-lines tax and stamping office

Reported tax rate: 3% of gross premium (2% for eligible surplus-lines risk retention groups) Pennsylvania charges 3% of gross surplus-lines premiums (2% for an eligible surplus-lines risk-retention group); the tax is in addition to premium, is borne by the insured, and is collected by the producer. For multistate risks, the 2025 Revenue instructions say all gross premiums are taxable when Pennsylvania is the home state, while Insurance Company Law §1621(d) says tax is levied only on premium reasonably ascribable to Pennsylvania risk; confirm allocation with your producer or the state. Surplus-lines coverage is excluded from the guaranty association, and qualifying large risks or exempt commercial purchasers may use distinct no-search routes, with the ECP route requiring disclosure and written request. 6,7,8,9

Providers With Documented State Licenses

These providers publish a national listing for Employment practices liability; the state records document licenses for the entities and roles shown below. Some records rely on company-reported information rather than independent regulator verification. A national listing does not confirm the product is available in Pennsylvania. Check the regulator’s license lookup and confirm state availability for your business when requesting a quote.

  • CoalitionCoalition Insurance Solutions, Inc.Insurance producer, Surplus-lines broker · checked 2026-09-28Coalition’s license page lists producer and surplus-lines licenses for Coalition Insurance Solutions, Inc. in all 50 states and the District of Columbia. The page separately lists insurers; this record covers the brokerage entity only. 11
  • CorgiCorgi Insurance Services, Inc.Insurance producer · checked 2026-09-28Corgi’s company producer-license table lists 50 jurisdictions: 49 states and the District of Columbia, including DC license 3003091619. New Mexico does not appear in the table and is not included here; the omission does not establish that Corgi is unlicensed there. The company-reported table has no stated as-of date and does not establish product availability. 12
  • TechInsuranceSpecialty Program Group LLCInsurance producer · checked 2026-09-28TechInsurance’s current licensing page names Specialty Program Group LLC / SPG Insurance Solutions and lists state license numbers, but labels Rhode Island “Individual licenses” rather than identifying a license for the named agency. RI is omitted because this disclosure does not establish agency authority there; this is a search limitation, not an assertion that the company is unlicensed. The remaining state entries are company-reported and are not an insurance product availability map. 15
  • VouchVouch Specialty Insurance Services, LLCInsurance producer, Surplus-lines broker · checked 2026-09-28Vouch’s licenses page, effective January 16, 2025, lists producer licenses in all 50 states and DC. Its separate surplus-lines table includes Idaho number 870820, while a footnote says Georgia and Idaho do not issue agency-level surplus-lines licenses. Because those statements conflict for Idaho, this record keeps Idaho producer-only and does not treat the table number as established agency surplus-lines authority. The page is company-reported and does not establish product availability. 16

Questions to Ask Before You Buy in Pennsylvania

  1. Which legal entities meet the four-person threshold in Pennsylvania, and which employees count?
  2. Does the business have a religious, fraternal, charitable, or sectarian status relevant to the allegation?
  3. Does the policy’s notice language trigger on the PHRC complaint or earlier intake materials?
  4. How will the company coordinate the PHRC process and any court action with the insurer?

Employment Practices Liability in Pennsylvania: FAQ

Does the PHRA generally apply to a company with four employees? 1,2

The statute defines employer to include a person employing four or more persons within Pennsylvania, but the definition also has detailed entity and employee exclusions. Check the full statutory definition for the specific organization. 1,2

What does PHRC say about the deadline and court option? 2

The agency’s current guidance says the general complaint period is 180 days. It says court action may be brought within one year after filing if the complaint remains unresolved or PHRC dismisses it. Get legal advice on the specific route and dates. 2

Employment Practices Liability in Other States

Other Coverage in Pennsylvania

Sources

  1. Pennsylvania Human Relations Act §4, Definitions. Pennsylvania General Assembly; §4(b) employer definition and entity exceptions; §4(c) employee exclusions. Accessed 2026-09-28.
  2. Filing a Complaint. Pennsylvania Human Relations Commission; Current agency guide, 180-day general period, respondent service and one-year court option; accessed 2026-09-28. Accessed 2026-09-28.
  3. pennsylvania insurance regulator. State insurance regulator; PID official agency page and the search/consumer-help service map. Accessed 2026-09-28.
  4. Pennsylvania Insurance Industry Search Tool Library. State insurance regulator; PID identifies consumer Sircon and detailed individual, business-entity, and company search tools. Accessed 2026-09-28.
  5. File a Complaint with Your Insurance Company, Agent, Broker, or Public Adjuster. State insurance regulator; PID directs insurance complaints and questions to its Consumer Services Online portal. Accessed 2026-09-28.
  6. RCT-123 Gross Premiums Tax - Surplus Lines Agents (2025). Pennsylvania Department of Revenue; Instructions p. 4, imposition/base/rate: 3% on gross premiums; insured bears tax, producer collects/remits; RRG exception 2% per statute. Accessed 2026-09-28.
  7. Insurance Company Law, §1621. Pennsylvania General Assembly; Subsection (d): multi-state tax is levied only on premium reasonably ascribable to Pennsylvania risk. This differs from the 2025 RCT-123 instructions, which state all gross premiums taxable if PA is home state; see source tax. Accessed 2026-09-28.
  8. Insurance Department Act, surplus-lines notice provision. Pennsylvania General Assembly; Policy legend: insurer is not licensed and surplus-lines insurance is NOT covered by Pennsylvania Insurance Guaranty Association. Accessed 2026-09-28.
  9. Pennsylvania Insurance Company Law §§1604 and 1610 (40 P.S. §§991.1604, 991.1610). Pennsylvania General Assembly; Act 28 of 2011 §1610(a), (a.1): large-risk criteria and ECP disclosure followed by written request exempt from diligent-search requirements. 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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