Texas Windstorm Certification: WPI-8 Triggers and 15% Surcharge

Texas windstorm certification is a WPI-8 Certificate of Compliance issued by the Texas Department of Insurance confirming that a coastal structure meets the building code standards required for wind and hail coverage. The Texas Windstorm Insurance Association will not write or renew a policy on a property that needs one and doesn’t have it.¹ For most coastal homeowners, no WPI-8 means no insurable wind coverage, which in turn means a mortgage problem.

Who Needs a WPI-8

Certification applies to properties in the 14 first-tier coastal counties: Aransas, Brazoria, Calhoun, Cameron, Chambers, Galveston, Jefferson, Kenedy, Kleberg, Matagorda, Nueces, Refugio, San Patricio, and Willacy. It also covers the parts of Harris County east of Highway 146 and inside the city limits of La Porte, Morgan’s Point, Pasadena, Seabrook, and Shoreacres.²

The requirement has applied to any structure built, altered, enlarged, or repaired on or after January 1, 1988. Work done on that date or later must comply with the windstorm building code under TWIA’s plan of operation for the property to be considered insurable.³ Older buildings follow different rules, covered below.

What Triggers an Inspection

Texas Insurance Code Section 2210.207 requires inspection and a certificate of compliance for new construction and for alterations, additions, or structural repairs. Roof replacements, new siding installations, and full window or door replacements that include the frames are common triggers.⁴⁵

Two exceptions matter. Repairs or maintenance with no structural changes never need inspection. And even structural repairs are exempt if the total cost is under $10,000.⁵ The threshold is strict. A structural repair that comes in at $9,500 is fine; the same work at $10,200 pulls you into the full certification process.

Repairs That Do Not Require an Inspection

TDI publishes a list of work considered non-structural or minor enough to skip certification:⁶

Interior work: cabinets, non-load-bearing partitions, painting, carpeting, refinishing, and plumbing or electrical repairs.
Storm preparation and temporary post-storm repairs.
Wall covering replacement under 10% of the affected wall’s surface area, soffit replacement for soffits less than 24 inches wide, and fascia repairs.
Replacing window glass, glass doors, or exterior side-hinged doors without replacing frames, as long as the replaced area is under 10% of the affected wall’s surface. Storm doors and screen doors installed outside an exterior door are also exempt.
Roof repairs covering less than 100 square feet, provided no decking or framing is involved.
Gutter replacement, fence repairs, stair and ramp repairs, and porch handrail or guardrail repairs.
Leveling a slab-on-grade or pier-and-beam foundation, as long as wall or foundation anchorage is not altered.

The glass exemption trips people up. Replacing a broken pane is exempt. Pulling out the frame is not, because the frame is part of the building envelope. If your contractor is removing frames, you need an inspection.

How to Get Certified

Before construction starts, the property owner or contractor files Form WPI-1, the Application for Certificate of Compliance, through TDI’s online windstorm system. The form captures the property address, a description of the work, and the contractor’s information.⁷ Filing the WPI-1 first establishes which building code edition and wind zone apply to the project. Starting work without filing pushes you onto the harder, more expensive path for already-completed construction.

For ongoing construction, two kinds of inspectors can do the work: TDI’s own field inspectors and Appointed Qualified Inspectors, who are Texas-licensed professional engineers that TDI has approved for windstorm inspections.⁸ TDI field inspectors charge no fee. AQIs set their own rates, and TDI does not regulate what they charge. The trade-off is availability versus cost: TDI inspectors are free but can be slow during hurricane season and peak building months, while an AQI generally schedules faster. TDI maintains a searchable list of appointed inspectors and the types of inspections they perform.

Inspections happen in phases, not all at the end. Inspectors need to see structural components before drywall, siding, or roofing covers them up: foundation and anchorage, wall framing and bracing, roof-to-wall connections, and final exterior closure. Missing a phase can force destructive testing or outright rejection, so inspection timing has to be coordinated with the contractor’s schedule.

After each phase, the inspector submits an Inspection Verification form (WPI-2) to TDI, stating that the construction meets the applicable building code.⁹ TDI has oversight authority to audit any inspection and can refuse to issue a WPI-8 if the structure does not meet windstorm standards.¹⁰ Once the final verification is in and the documentation checks out, TDI issues the WPI-8 Certificate of Compliance.⁴ The WPI-8 is what you provide to TWIA. Once issued, the certificate cannot be rescinded.¹¹

Processing time depends on TDI’s workload, and there is no guaranteed turnaround. If a policy issuance or renewal deadline is pressing, start the inspection process early.

The 2024 Building Code Change on April 1, 2026

Starting April 1, 2026, all new WPI-1 applications must certify compliance with the 2024 editions of the International Residential Code and International Building Code.¹² Projects that started before that date can still certify under the previous code edition, but anything new must meet the 2024 standards. Submitting under the wrong edition after April 1, 2026 will result in rejection.¹³ The updated codes include revised windborne debris protection requirements, so confirm with your contractor and inspector that designs reference the 2024 editions.

Historic structures listed on the National Register of Historic Places, designated as Recorded Texas Historic Landmarks, or recognized by a local authority as historically significant and at least 50 years old may be exempt from the new code requirements.¹³

If the Work Is Already Finished

Construction that finished without a WPI-1 can still be certified, but through a different and more burdensome process. TDI issues a WPI-8E certificate for completed improvements.¹⁴ A completed improvement is one where the original title transfer from builder to initial owner has occurred, or where the work is substantially finished.

To get a WPI-8E, a licensed professional engineer must do one of two things:¹¹

The engineer who designed the improvement affirms under seal that the design complies with the applicable building code and that the construction followed the design.
Any licensed PE conducts a sealed post-construction evaluation confirming the completed work meets code, supported by documentation.

Either way a professional engineer is involved, so free TDI field inspections are not an option on this path.¹⁴ The engineer submits a WPI-2E application with the sealed report, and TDI may deny the application if the report is incomplete. The department’s forms cannot require the engineer to assume liability for the construction itself, only for the accuracy of their evaluation.¹¹ Engineers evaluating finished work often have to rely on indirect evidence because they cannot see connections hidden behind walls and roofing, which is why the post-construction route is more expensive and less certain than filing a WPI-1 before work begins.

Older Properties and the 15% Surcharge

January 1, 1988 is the dividing line. Properties built before that date in areas covered by a TWIA-recognized building code at the time of construction are eligible for coverage without any inspection or certificate. Pre-1988 properties in areas without a recognized code can still qualify if the structure was previously insured by an authorized Texas insurer and remains in essentially the same condition apart from normal wear.³ The grandfather clause protects the existing structure; any new structural work on an older building triggers the modern certification requirements for that work.

A separate rule applies to properties built between January 1, 1988 and June 18, 2009 that never obtained a WPI-8. TWIA will insure them, but at a 15% surcharge on top of the full policy premium for each term. The surcharge is calculated on the final total premium, is not commissionable to the agent, and is not refundable.¹ If the owner later obtains all missing certificates, the surcharge drops off at the next renewal, but TWIA will not refund surcharges already paid during the current term.¹⁵ On a $3,000 annual premium, that is $450 a year. Getting a retroactive WPI-8E through the completed-construction process usually costs less than carrying the surcharge year after year.

Properties where construction began after June 18, 2009 do not get the surcharge option. Without a WPI-8, they are simply ineligible for TWIA coverage.

If an Inspection Fails

A failed inspection adds time and cost but is not fatal to the project. When a TDI inspector finds non-compliance, they post a notice at the job site describing the specific problems. The owner or contractor corrects them, and the inspector returns for a re-inspection.⁸ If you want a different set of eyes or faster scheduling, you can switch to an appointed private engineer to complete the remaining inspections. TDI does not penalize property owners for switching mid-project.

1
Texas Windstorm Insurance Association. Windstorm Certification
2
Texas Windstorm Insurance Association. Coverage Eligibility
3
State of Texas. Texas Insurance Code Chapter 2210 – Texas Windstorm Insurance Association
4
Texas Department of Insurance. What You Need to Know About Windstorm Inspections
5
State of Texas. Texas Insurance Code 2210-207 – Certificate of Compliance
6
Texas Department of Insurance. Repairs That Do Not Require a Windstorm Inspection
7
Texas Department of Insurance. Application for Certificate of Compliance Form WPI-1
8
Texas Department of Insurance. Windstorm Inspection Program – Inspection Process
9
Texas Department of Insurance. Inspection Verification Form WPI-2
10
Legal Information Institute. Texas Administrative Code 28 5.4640 – Oversight
11
State of Texas. Texas Insurance Code 2210.2515 – Issuance of Certificates of Compliance
12
Texas Department of Insurance. Adopted Building Codes
13
Texas Department of Insurance. Texas Administrative Code 5.4013 – Applicable Building Code Standards
14
Texas Department of Insurance. Completed Construction Certificates
15
Texas Windstorm Insurance Association. TWIA Instructions and Guidelines Manual