Would you consider a moveable appliance such as a refrigerator or washing machine placed in front of a residential sub panel a violation of 110.26?

By the book....2014....I would say yes.

The fridge would make the panel ‘hidden’; the washing machine is more than likely heavy, and has water supply & drain hose. If you are talking a ‘stackable’ (washer/dryer) that falls under ‘hidden’.

Opinions?? Gentlemen.

It is a violation but not one that will never be found unless they open a permit for something else.
The NEC process pretty much stops when the customer moves in and closes the door.
The best hope is an insurance inspector sees it before it is a fireman on a run.

It was the home inspector that pointed it out.

Hmmm... very interesting.

Every great once in a while a Home Inspector will actually do a good job with the electrical.

I'm surprised but it might be that more states are actually requiring more training and certification for Home Inspectors. It used to anyone with a flashlight and a clip board could call themselves a home inspector.

Greg made two good points. Yes, an inspector (NJ) cannot enter unless there is an open permit, or there is reason of imminent danger/unsafe conditions.

Secondly, yes the home inspectors are becoming a little more 'electrical' oriented here. NJ adopted a license for HIs and it helps a lot.

FWIW, my original comment above was IF it was blocked during an inspection.

Just walking around looking at people's homes, I seldom actually find a panel that meets 110.26 in the strictest sense. It seems that when the original electrician placed it and established working space in front of it he also created an open space that seems to good to waste for the homeowner. There always seems to be something stored there.
When I set the panel in my house I built it into a small enclosure that is too shallow to actually let you store anything inside and centered behind a 32" bi fold door. So far my wife has not tried to put anything there. I think blocking a door is just not something people are likely to do,.
The door allows ready access and if you really need to get into the panel, the door lifts off the pins and you can set it aside giving you 32" of clear space. (it is still around 30 with the door open).