VA Loan Termite Inspection: The Rule and Who Pays

A VA loan needs a wood destroying pest inspection when the Notice of Value says it does, and not otherwise. Where that condition appears, the veteran is allowed to pay the fee, which has been true since 15 June 2022 and is still repeated wrongly all over the internet.

Nothing here has to be settled today. The Notice of Value comes back after the appraisal, and until it does, there is no condition to satisfy and no fee to argue about.

By the end of this you will know what makes the requirement attach to your file, exactly what changed in 2022, and where in the federal regulation the permission to charge you actually lives, which turns out not to be where you would look for it.

Does a VA loan require a termite inspection?

Only for some properties, and the trigger is a map plus a document.

Circular 26-22-11 sets out the requirement in one sentence: “VA requires, as a Minimum Property Requirement, a wood destroying pest inspection report for certain properties located in an area on the Termite Infestation Probability Map where the probability of termite infestation is ‘very heavy’ or ‘moderate to heavy.’” Those two quoted phrases are zone labels on the map, and they are the whole of the geographic test.

The circular then says what happens to a file that falls inside one: “If applicable, the VA Notice of Value (NOV) will be conditioned for this requirement and MPR repairs identified on a wood destroying pest inspection report must be completed prior to guaranty.”

So the Notice of Value is the document that answers this for your purchase. Not a blog, not a map you found, and not a lender’s recollection. If the report is listed there as a condition, you need one. The rest of what a buyer gets out of that report is in my guide to a termite inspection for home buyers.

Can the veteran pay for the inspection?

Yes, where the Notice of Value requires the inspection. The pre-2022 claim that a veteran can never pay is out of date, and the circular is explicit about what it replaced.

Its Background paragraph describes the old position: “Historically, VA has authorized, as a local variance, that Veterans may be charged for a wood destroying pest inspection report in a limited number of states and territories.” A local variance in a limited number of places is exactly the kind of rule that gets repeated as a national ban by anyone standing outside those places.

Its Action paragraph replaces that: “Effective immediately, VA is authorizing in advance, as a local variance, that Veterans may be charged wood destroying pest inspection fees, where required by the NOV. Veterans may also pay for any repairs required to ensure compliance with MPRs. Veterans are encouraged to negotiate the cost of the wood destroying pest inspection and repairs with the seller.”

Three things are packed in there. The fee may be charged to the veteran. So may the repair costs that the report generates. And VA’s own suggestion is that both are negotiable with the seller, which is the sentence to have open when the subject comes up. The broader buyer-and-seller version of that argument is in who pays for a termite inspection.

The circular also says of itself: “This Circular is valid until rescinded.” There is no expiry date to check.

Why does the regulation behind the fee never mention termites?

Because the fee is not on the regulation’s list. It arrives through the clause at the end that covers everything else.

Footnote 1 of the circular, attached to that sentence about historical local variances, cites 38 C.F.R. § 36.4313(d)(1)(ix). Paragraph (d)(1) of that regulation opens with “The veteran may pay reasonable and customary amounts for any of the following items:” and then enumerates them. Subparagraph (ix), the one cited, reads in full:

“Such other items as may be authorized in advance by the Under Secretary for Benefits as appropriate for inclusion under this paragraph (d) as proper local variances.”

My read of the two documents together is that this is the whole mechanism. A pest inspection fee is not an enumerated item a veteran may pay; it is an “other item”, and it becomes payable when the Under Secretary for Benefits authorises it in advance as a local variance. Circular 26-22-11 does that in terms, in its Action paragraph, and it is signed by direction of the Under Secretary for Benefits.

That is worth knowing for a practical reason rather than a legal one. If somebody tells you to point at the regulation that permits the charge, the regulation on its own will not settle it. The circular is the document that does the work, and it says on its face that it remains valid.

What did Change 1 change?

One footnote, six weeks later, and nothing about who pays.

Circular 26-22-11 Change 1 is dated 28 July 2022 and states its own purpose: “The purpose of this Circular is to update the footnote for the Termite Infestation Probability map in section 2.” The substance of the change is a single paragraph: “Page 1, paragraph 2: footnote 2 previously cited as Termite Infestation Probability Map, Adapted from the 2021 International Residential Code (IRC), Figure R301.2(7) | Building America Solution Center (pnnl.gov) is updated to VA Lenders Handbook M26-7, Chapter 12, Topic 33.”

Read the two halves of that. When the circular was published, the authority it gave for its own map was a Pacific Northwest National Laboratory web page rendering a figure from the 2021 International Residential Code. Six weeks later the citation points at VA’s own handbook instead.

The rule did not move. The map did not change. What changed is where VA sends you to find it, and the practical effect for a buyer is that the zone question is now answered inside VA’s lending guidance rather than by a building-code figure hosted elsewhere. Change 1 also repeats that the circular “is valid until rescinded.”

Which form does the inspection produce?

Form NPMA-33 in most of the country, and a state form where the state prescribes one.

The NPMA-33’s own footer says “This form is approved for FHA and VA loans.” Two of its printed conditions matter to a closing timetable. It states that the report “shall be considered invalid for purposes of securing a mortgage and/or settlement of property transfer if not used within ninety (90) days from the date of inspection”, and immediately afterwards that “This shall not be construed as a 90-day warranty.” Those are two separate ideas that get merged constantly. One is a shelf life for lending purposes; the other is a denial that anything is being warranted. My line-by-line reading of the form is at what a WDI report means.

Several states displace or subordinate that form. California’s Structural Pest Control Board says “The WDO Report (form 43M-41) supersedes the NPMA-33 form in California”, and where an inspector does complete an NPMA-33, “it must be provided as an attachment to the WDO Report (form 43M-41).” Texas treats a lender’s form as an add-on: under 4 TAC §7.176(b) it “is supplemental to the required department form and must be maintained in the inspection file.” Georgia’s rules make the Official Georgia Wood Infestation Inspection Report the instrument “for the purpose of certifying that a structure is apparently free from wood destroying organisms as a basis for transfer of real property”. Which applies at your address is in my state-by-state guide.

Whoever completes it has to be licensed. The EPA’s guidance is that “Firms offering termite services must be licensed by your state”, and Section I of the NPMA-33 has a printed field for the company’s pest control business license number, so the claim and its evidence arrive together.

What has to be in the loan file?

An itemised invoice, and it has a specific job.

Circular 26-22-11 states: “An itemized invoice identifying the Veteran and the property is required to verify the cost on the Closing Disclosure Statement (CD).” It continues: “Lenders should include the invoice(s) to support the cost of the inspection and any repairs in the loan file if the loan is selected for Full File Loan Review (FFLR).”

The invoice has to name the veteran and the property, because the point of it is to tie a line on the Closing Disclosure to a real piece of work at a real address. Ask for it in that form when you book the inspection rather than after closing, when the company has no particular reason to reissue anything.

Here’s what I’d actually do

I would read the Notice of Value before reading anything else about this, including this page. Before it arrives, you can see what VA is likely to condition it on: my lookup of the states and counties where a VA loan requires a termite report reproduces VA’s own list whole.

Everything downstream turns on whether a wood destroying pest inspection report is listed there as a condition. If it is not, there is no VA requirement on your file and the fee question does not arise. If it is, the requirement is real, the repairs the report generates have to be done before guaranty rather than after closing, and that timing is the part worth planning around.

If somebody tells you a veteran cannot pay, I would quote the Action paragraph rather than argue about it, and then take VA’s own advice and try to put the cost on the seller anyway. Being allowed to pay for something is not the same as being the obvious person to pay for it.

When you book the inspection, I would ask for the itemised invoice naming you and the property up front, and check that the inspection date leaves comfortable room inside ninety days of your expected closing. If the report comes back with findings, that is an ordinary outcome rather than a stopped deal, and I have written separately about a report that comes back with findings.

I have not seen your Notice of Value, your appraisal or your lender’s own overlays, and any of the three can change what happens next. The documents above are the ones that decide what VA permits.

Sources

• Circular 26-22-11: Pest Inspection Fees and Repair Costs — Veterans Benefits Administration, US Department of Veterans Affairs, published 2022-06-15. Accessed 2026-08-06.
• Circular 26-22-11 Change 1: Pest Inspection Fees and Repair Costs — Veterans Benefits Administration, US Department of Veterans Affairs, published 2022-07-28. Accessed 2026-08-06.
• 38 CFR § 36.4313, Charges and fees — Electronic Code of Federal Regulations, US Government Publishing Office. Accessed 2026-08-06.
• Form NPMA-33: Wood Destroying Insect Inspection Report — National Pest Management Association, hosted by the US Department of Housing and Urban Development, form dated 2019-07-01. Accessed 2026-08-06.
• Termites: How to Identify and Control Them — US Environmental Protection Agency, updated 2025-10-21. Accessed 2026-08-06.
• Frequently Asked Questions Regarding the Use of the National Pest Management Association’s Wood Destroying Insect Inspection Form (NPMA-33) in California — California Structural Pest Control Board, undated. Accessed 2026-08-06.
• Instructions for the Texas Official Wood Destroying Insect Report (Form SPCS/T-5) — Texas Department of Agriculture, revised 2019-09-01. Accessed 2026-08-06.
• Rules of the Georgia Structural Pest Control Commission, Rule 620-6-.03 — Georgia Department of Agriculture, effective 2026-04-08. Accessed 2026-08-06.