WDO Report Requirements by State
Fifteen states require their own inspection form. The rest accept the NPMA-33. And then there's the VA, which has its own set of rules on top of everything. Here's how to figure out which form you need for any given inspection.
The two-tier system
WDO reporting in the U.S. works on two levels. At the federal level, the NPMA-33 is the standard form for all HUD/VA/FHA transactions. At the state level, 15 states require their own form — and when a state mandates its own form, that form takes priority over the NPMA-33 for state purposes. But the lender may still require the NPMA-33 on top of the state form.
The result: if you're doing a VA-financed inspection in California, you're completing two forms. If you're doing the same inspection in, say, Ohio, you're completing one.
States with their own forms
According to the NPMA, the following 15 states require state-specific inspection forms: Alabama, Arizona, California, Florida, Georgia, Hawaii, Louisiana, Maryland, Mississippi, Nevada, North Carolina, Oklahoma, South Carolina, and Texas. In these states, the state form is the primary document.
Here are the ones inspectors ask about most, with the details that actually matter:
California — Form 43M-41
"Wood Destroying Pests and Organisms Inspection Report" — the most demanding system in the country. Only Branch 3 licensees can inspect and file. Uses the Section 1/Section 2 classification system (unique to California). Must be filed with the SPCB within 10 business days at $4 per property. Reports are public records for 2 years. The form covers both insects and organisms (fungi, dry rot). For VA/FHA transactions, the NPMA-33 is also required as an attachment.
For the full breakdown: California 43M-41 vs. NPMA-33: When Do You Need Both?
Florida — FDACS-13645
"Wood-Destroying Organisms Inspection Report" — regulated by the Florida Department of Agriculture and Consumer Services (FDACS). Florida's form has a notably broader scope than the NPMA-33: it defines wood-destroying organisms as including termites, powder post beetles, old house borers, AND wood-decaying fungi. Most states' forms (and the NPMA-33) cover insects only. Florida also requires a Notice of Inspection to be posted at the structure when the form is issued.
Texas — Form SPCS/T-5
"Texas Official Wood Destroying Insect Report" — regulated by the Texas Department of Agriculture, Structural Pest Control Service. Note: the current form is the T-5 (revised September 1, 2020), not the T-4 referenced in some older guides. Covers insects only, not organisms. Inspection companies must retain a copy for a minimum of 2 years.
South Carolina — CL-100
Officially the "Official South Carolina Wood Infestation Report," universally known as the CL-100. Regulated by Clemson University's Department of Pesticide Regulation — one of the only states where a university serves as the regulatory body. The CL-100 has a broader scope than the NPMA-33: it covers wood-destroying insects, fungi (below the first main floor level), and excessive moisture conditions. The report is widely cited as being valid for 30 days from inspection — compared to the NPMA-33's 90 days.
Oklahoma — ODAFF-1
"Oklahoma Official Termite and Wood Destroying Insect Report" — regulated by the Oklahoma Department of Agriculture, Food, and Forestry. Covers insects only (the form explicitly states it does not address molds or wood destroying organisms). The current version's adoption date is January 1, 2020. Oklahoma also uses a separate ODAFF-2 form for corrections or alterations after an ODAFF-1 has been issued.
Arizona — WDIIR
"Wood Destroying Insect Inspection Report" — regulated by the Arizona Department of Agriculture, Pest Management Division. The form explicitly states it is not a structural damage or fungi/mold report. Only Certified Applicators may complete the WDIIR — technicians are not permitted (per A.R.S. § 3-3633(A)). Notably, Arizona state law does not itself require a WDIIR for the sale of a structure — the inspection is typically a lender requirement, not a state mandate. The state only requires that WDIIRs, when completed, meet certain minimum standards.
Everyone else: the NPMA-33 states
The remaining roughly 35 states plus the District of Columbia use the NPMA-33 as their primary WDI inspection form. There's no state-specific form to worry about — you complete the NPMA-33, and that's your report.
However, "no state-specific form" doesn't mean "no state requirements." States still vary in who can perform inspections, what licensing is required, and whether any reporting obligations exist. For example, Arkansas requires WDI inspectors to maintain a $100,000 surety bond and $500,000 per occurrence general liability insurance (per Arkansas Code § 17-37-210) — one of the highest financial barriers in the country.
For the full guide to the NPMA-33 itself: How to Fill Out the NPMA-33 Form
VA loan requirements: another layer
On top of whatever the state requires, the VA has its own rules about when a WDI inspection is needed for VA-guaranteed loans. The VA uses the USDA Forest Service Termite Infestation Probability Map to determine which areas require inspections.
As of the VA's Local Requirements page (last updated July 11, 2025), 30 states plus D.C. require WDI inspections statewide for VA purchase loans and cash-out refinances. An additional 8 states require inspections in specific counties only.
States with statewide VA WDI requirements include: Alabama, Arizona, Arkansas, California, Connecticut, Delaware, Florida, Georgia, Hawaii, Illinois, Indiana, Kansas, Kentucky, Louisiana, Maryland, Massachusetts, Mississippi, Missouri, New Jersey, New Mexico, North Carolina, Ohio, Oklahoma, Rhode Island, South Carolina, Tennessee, Texas, Virginia, and West Virginia.
States with county-specific requirements include Colorado, Iowa, Nebraska, Nevada, New York, Pennsylvania, Utah, and Wisconsin.
Colorado was historically exempt from VA termite inspection requirements due to its dry climate. That changed in mid-2025, when the VA added 43 Colorado counties to its required inspection list — including El Paso County (Colorado Springs) and Pueblo, but notably excluding Denver and Boulder counties. This was not announced through a VA Circular — it appeared directly on the VA website, catching many Colorado-area real estate professionals off guard.
For all VA loans where a WDI inspection is required, the NPMA-33 or a state-approved equivalent is the accepted form. Reports are considered valid for 90 days. If active infestation or structural damage is found, treatment and repairs must be completed before the loan can close. Since VA Circular 26-22-11 (June 2022), veterans are now permitted to pay for the WDI inspection fee — a change from the prior rule.
The core problem for multi-state operators
If you inspect in one state, you learn one set of rules and stick with it. But if you operate near a state border — or if you're part of a company that covers multiple states — the form patchwork becomes a genuine compliance headache. Each state form has different fields, different terminology, different filing requirements, and different scopes (insects only vs. insects and organisms).
NPMA maintains a "WDO State Inspection Certification Requirements" spreadsheet (available on their Forms Information page at npmapestworld.org) that details the licensing and certification requirements for each state. It's worth downloading if you operate in multiple states or are expanding into a new market.
Last updated April 2026. Regulatory requirements change frequently — always verify current rules with your state regulatory agency and lender. Primary sources: NPMA Forms Information page (npmapestworld.org), VA Local Requirements (benefits.va.gov/HOMELOANS/appraiser_cv_local_req.asp), individual state regulatory agencies (SPCB, FDACS, TDA, Clemson DPR, ODAFF, AZDA), Arkansas Code § 17-37-210, HUD Handbook 4000.1. The NPMA also publishes a WDO State Inspection Certification Requirements spreadsheet updated as of June 2025.