Compliance and payroll

What a subcontractor COI should include

A usable subcontractor COI names the same legal entity that signed your subcontract, lists every required policy with current dates and limits that meet the contract, marks additional insured and waiver of subrogation where required, describes your project, and names you as certificate holder. The endorsements behind those checkmarks should come attached.

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A subcontractor certificate of insurance should show five things you can verify in two minutes: the right insured, the right policies, limits at or above your contract minimums, dates that cover the whole job, and the additional insured and waiver boxes your subcontract requires. Most certificates in construction arrive on the ACORD 25 form, so the review is the same every time once you know where each item sits.

What follows is a field-by-field walk through that form, with what to look for in each box and the problems that show up most often.

The ACORD 25 at a glance

The top of the form carries a disclaimer: the certificate is issued as a matter of information only, confers no rights on the certificate holder, and does not amend, extend, or alter the policies. It then says that if the holder is an additional insured, the policy must be endorsed. Read that as instructions. The certificate is a summary. The endorsements are the coverage.

ACORD 25 sections and what to check
SectionWhat to check
ProducerThe broker or agent who issued it, with a contact name, phone, and email you can call
InsuredExact legal name and address of the sub that signed your subcontract
Insurers A to FEach carrier's name and NAIC number, matched to the policy lines by letter
CoveragesPolicy type, ADDL INSD and SUBR WVD columns, policy number, effective and expiration dates, limits
Description of operationsProject name and address, list of additional insureds, special wording required by your contract
Certificate holderYour company's correct legal name and mailing address
CancellationStandard wording says notice will be delivered per policy provisions, which may be less than you expect

Field-by-field review checklist

1. Named insured

Match the name character for character against the subcontract and the sub's W-9. A certificate for ABC Mechanical LLC does not cover ABC Mechanical Services Inc. This is the single most common mismatch, and it usually means the sub has two entities and sent the wrong certificate.

2. Commercial general liability

Check occurrence versus claims-made (construction contracts usually require occurrence), the each occurrence limit, the general aggregate, and the products and completed operations aggregate. The form also has a box showing whether the general aggregate applies per policy, per project, or per location. A per-project aggregate keeps a claim on another job from eating the limit available for yours, so many contracts require it.

3. Automobile liability

Look at which autos are covered: any auto, owned, scheduled, hired, or non-owned. A sub with only scheduled autos may have no coverage for the pickup a foreman borrowed. Compare the combined single limit to your requirement.

4. Umbrella or excess liability

Confirm the occurrence and aggregate limits and whether the policy follows form over the GL, auto, and employer's liability. If your contract lets the sub meet the GL limit by stacking umbrella on top of a smaller primary policy, write that down so the reviewer does not reject a compliant certificate.

5. Workers compensation and employer's liability

The statutory box should be checked, and the employer's liability limits filled in for each accident, disease per employee, and disease policy limit. Note the question about excluded owners, partners, or officers. If the owner is excluded and works on site with tools, talk to your broker about what that means for your own workers compensation audit. Rules differ by state, so see workers compensation for contractors explained. Some public owners also require a state-issued workers comp form instead of, or in addition to, the ACORD.

6. ADDL INSD and SUBR WVD columns

An X in the additional insured column and the waiver of subrogation column tells you the broker believes those endorsements exist. Ask for the forms themselves. For general liability, contractors commonly see ISO forms CG 20 10 (ongoing operations), CG 20 37 (completed operations), CG 20 38 (automatic status when required in a written construction agreement), CG 20 01 (primary and noncontributory), and CG 24 04 (waiver of subrogation). On workers comp, the waiver often comes from the NCCI form WC 00 03 13. Those are examples, not a requirement list; your subcontract decides.

7. Policy dates

Every effective date should be on or before the sub's start date, and every expiration date goes in your tracker. If a policy expires before the scheduled finish, you will need a renewal certificate. That is normal; just log it.

8. Description of operations

This box should name the project and address and list every party your contract requires as additional insured, usually the owner, the GC, and sometimes the lender, architect, or construction manager. Contract-specific notice wording goes here too. One New York public owner's sample instructions tell brokers to show its 30 day notice of cancellation terms in this box or attach the endorsement.

Worked example: reviewing a plumbing sub's COI

Say the subcontract for a $1.2 million medical office build requires $1,000,000 per occurrence and $2,000,000 aggregate GL with a per-project aggregate, $1,000,000 auto, a $5,000,000 umbrella, and statutory workers comp with $1,000,000 employer's liability limits, plus additional insured status for owner and GC on ongoing and completed operations. The certificate arrives and the coordinator finds:

  1. Named insured matches the subcontract. Pass.
  2. GL limits meet the minimums, but the aggregate box is checked per policy, not per project. Fail.
  3. Umbrella shows $2,000,000. Fail, $3,000,000 short.
  4. ADDL INSD is checked on GL, and only the ongoing operations endorsement is attached. Partial.
  5. Description of operations lists the GC but not the owner. Fail.

The coordinator sends one email to the broker listing all four gaps at once, not four separate emails over two weeks. The sub stays off site until a revised certificate and the missing endorsements come back.

Red flags on a subcontractor COI

  • Handwritten changes, mismatched fonts, or edits to the disclaimer text.
  • No producer contact information, or a producer you cannot reach.
  • A certificate dated months ago with no renewal on file.
  • Policy numbers listed as pending or TBD.
  • Language in the description box promising coverage that the endorsements do not support.

When to review the COI

Do the full review at buyout, before the subcontract is countersigned, while you still have leverage and time. Do a short review each time a renewal certificate arrives, because carriers, limits, and endorsement forms can change at renewal. And look again whenever the contract changes scope in a way that adds risk, such as a sub picking up crane work or roofing it was not originally hired for.

Related templates, terms, and tools

Log what you review in a subcontractor COI tracking template, then set renewal reminders using the process in how to track subcontractor insurance certificates. Related terms: waiver of subrogation, hold harmless clause, self-insured retention. Smart Business Automator can pull policy dates and limits from an uploaded certificate with document data extraction and flag expirations, as part of subcontractor compliance automation.

Frequently asked questions

What is an ACORD 25?

It is the standard certificate of liability insurance form used in the U.S. to summarize a business's liability and workers comp policies for a third party. It shows carriers, policy numbers, dates, and limits, but it does not itself grant coverage.

Should the GC be listed as certificate holder or additional insured?

Usually both. The certificate holder is who receives the certificate. Additional insured status is a coverage right created by an endorsement to the sub's policy, and it must be on the policy, not just written on the certificate.

Does a checked ADDL INSD box mean I am covered?

It means the broker indicates an additional insured endorsement exists. Ask for the endorsement form to confirm who it covers, whether it includes completed operations, and whether it is limited to your project.

What if the sub's limits are lower than my contract requires?

Do not let the sub start until the shortfall is fixed or you approve a written exception. Often the sub can add umbrella coverage, which the broker can show on a revised certificate.

Sources

  1. City of Sierra Madre, CA: Sample insurance for construction contracts (ACORD 25, CG 20 38, CG 20 37, CG 20 01, CG 24 04, WC 00 03 13)
  2. Dormitory Authority of the State of New York: Insurance requirements sample package (ACORD 25, CG 20 10, 30 day notice instructions)
  3. New York State Senate: Insurance Law section 502, certificates of insurance
Written and edited by

Maurice Francois writes and edits construction operations guides for Smart Business Automator. More from Maurice on the Scaling Legends podcast.

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