The 17 line-items every commercial GC and risk manager verifies on a sub’s ACORD 25. Developer-driven endorsements, owner/lender certificate-holder requirements, per-project aggregate, builder’s risk verification.
Why this checklist exists
The ACORD 25 Certificate of Liability Insurance is informational. It is not the contract. The certificate tells you a policy exists; the endorsements attached to that policy are what actually obligate the insurer to defend you when a slip-and-fall claim, a defective-work suit, or a third-party property damage demand lands on the project. On a commercial-construction job, a private office tower, a multi-tenant retail center, a hotel, a multi-family residential build, an industrial warehouse, a hospital expansion, the difference between a clean certificate and an enforceable endorsement set is the difference between a covered claim and a back-charge that lands on the GC and the developer simultaneously.
Every owner’s risk manager and every commercial-GC compliance officer eventually finds the same problem during a project audit: the GC collected a certificate that ticked the right boxes but never collected the actual endorsement copies. The “Additional Insured” box is checked, but the CG 20 10 endorsement form is nowhere in the file. The “Waiver of Subrogation” box is checked, but the CG 24 04 form is never produced. The certificate names the GC as additional insured, but the developer, the lender, the property manager, and the architect, every party listed on the indemnity schedule of the prime contract, are not on the certificate at all. When a claim hits, those missing names are the leverage points the carrier uses to deny the tender.
What makes a commercial review different from a federal review:
- Multiple certificate holders, not one. Federal projects typically name the prime as the single certificate holder. Commercial projects routinely require the GC, the owner, the developer, the lender, the property manager, the architect, the engineer of record, and any tenants of the building as additional insureds and certificate holders. A single missing party is a single missing tender right.
- Per-project aggregate is non-negotiable on developer work. Real-estate developers and institutional owners contract for dozens of projects simultaneously. They will not accept shared aggregate limits. The CG 25 03 endorsement is a hard requirement on most ground-up commercial work and most large tenant-improvement projects.
- Limit thresholds vary by project size, not by jurisdiction. Federal limits are set by FAR and agency supplements. Commercial limits are set by the prime contract, and they scale with project value, building height, occupancy classification, and lender requirements. A $5M tenant-improvement on a leased floor and a $500M mixed-use tower will sit on entirely different insurance schedules.
- Builder’s risk lives outside the ACORD 25. Commercial projects almost always carry a separate builder’s risk policy issued in the name of the owner or developer. The CGL on the ACORD 25 does not cover damage to the work itself. Confirm builder’s risk is in place separately, with proper named insureds, deductible allocation, and a soft-cost endorsement if delay coverage matters.
- Completed-operations tail tracks contract terms, not statute. Commercial GCs commonly require a 2-to-5-year completed-operations tail per the indemnity language in the subcontract. Some institutional owners require 10 years. The CG 20 37 endorsement and the products-completed-operations aggregate must remain in force across that entire window, not just the construction period.
- Cancellation notice often runs longer than 30 days. Some commercial primes, especially institutional-owner work and lender-financed projects, require 60-day or 90-day written notice of cancellation. Confirm the contract requirement before accepting the certificate’s default 30-day notice.
This checklist is the practitioner’s version. It’s the artifact a commercial-GC risk manager actually uses on every weekly COI review pass to flag the gaps that turn into withheld payments, denied tenders, and stop-work notices from the developer’s lender. Run it on every sub’s certificate before subcontract issuance. Re-run it on every renewal cycle and every time the sub adds scope or trades. Keep the completed checklist alongside each sub’s COI in the project file so when the developer’s risk manager asks for proof of compliance, the answer is one folder away, not a scramble.
Who uses this
- Commercial general contractors managing 75–400+ subcontractor COIs across active developer, institutional, and tenant-improvement projects
- Risk managers and compliance officers running weekly COI verification cycles across multiple concurrent commercial projects
- Project administrators and contract administrators chasing missing endorsements, late renewals, and out-of-date carriers
- Owner-side risk managers at real-estate developers, REITs, hospitality groups, and institutional owners verifying GC and sub coverage
- Construction lenders and surety underwriters reviewing flow-down compliance during draw approvals and bond renewals
What’s included. 17 line-items every commercial COI review hits
The checklist covers 17 things every commercial GC and owner-side risk manager must verify on every commercial-project ACORD 25. In the order an experienced reviewer works through the certificate:
- Producer and insurer A.M. Best rating verification. The certificate names a Producer (broker) and one or more Insurers. Verify each carrier’s A.M. Best rating directly at ambest.com. Most commercial primes require A- or better; institutional owners and lender-financed projects commonly require A- VII or A VIII (the Roman numeral is the financial-size category and matters for limits >$10M). A B+ carrier on a developer-financed project is a routine rejection trigger.
- Named insured matches subcontract legal entity exactly. “ABC Inc.” is not the same as “ABC Construction LLC” on a claim. The named insured field must match the subcontract signature block character-for-character. DBA’s, parent-subsidiary mismatches, and recently-renamed entities generate the most preventable coverage disputes on commercial work, especially on lender-financed projects where the lender’s compliance review will catch any name divergence.
- CGL limits scaled to project size. Standard commercial baseline is $1M per occurrence / $2M general aggregate / $2M products-completed-operations aggregate. Mid-size commercial commonly steps to $2M / $4M / $4M. Ground-up institutional, lender-financed, and high-occupancy work commonly requires $5M underlying or higher with the umbrella stacking on top. Confirm the limits column on the ACORD 25 matches what the prime contract, and the owner’s flow-down, requires.
- Per-project aggregate endorsement (CG 25 03) attached. Without CG 25 03, the policy aggregate is shared across every job the sub is on. A single large claim on a different developer’s project can exhaust the aggregate before yours pays out. Real-estate developers and institutional owners reject any sub COI without CG 25 03 on commercial work. Demand a copy of the endorsement, not just the box-check.
- Additional insured ongoing operations (CG 20 10) confirmed for all required parties. This endorsement extends coverage during the sub’s ongoing operations. The endorsement form number and edition date must appear in the Description of Operations, AND a copy of the actual endorsement must be on file. The endorsement must name every party the prime contract requires. Typically GC, owner, developer, lender, property manager, architect, and engineer of record. A missing party is a missing tender right.
- Additional insured completed operations (CG 20 37) confirmed. Companion endorsement to CG 20 10, covering liability after the sub’s work is completed. Commercial projects routinely have completed-operations tails of 2–5 years; institutional and hospital work runs longer. CG 20 37 is the form that keeps coverage in force during the tail. Many subs add CG 20 10 but skip CG 20 37. That is the single most common commercial finding.
- Additional insured for owner/lessee (CG 20 33 or CG 20 38) where required. When the GC is acting on behalf of an owner-developer with multiple LLCs, ground-lessees, or special-purpose entities holding title, CG 20 10 alone is not always enough. CG 20 33 (blanket additional insured tied to a written contract) or CG 20 38 (completed-ops blanket where required by contract) often becomes the cleaner mechanism. Confirm which form the prime contract calls for.
- Waiver of subrogation (CG 24 04) on CGL and on workers comp. The waiver prevents the sub’s insurer from later suing the GC, owner, lender, or other additional insureds to recover what they paid out. Required on both the CGL and the workers’ compensation policies. The CGL waiver is CG 24 04; the WC waiver is a state-specific form (varies by jurisdiction). Both must be confirmed and copied to the file.
- Primary and non-contributory wording explicit on CGL. Without explicit “primary and non-contributory” language, the GC’s and owner’s own insurance can be tapped before the sub’s. Defeating the purpose of additional-insured status. The wording must be explicit in the policy or via endorsement (often CG 20 01 or carrier-equivalent), not just implied. Check the Description of Operations and demand the endorsement copy. On commercial work, this is one of the top three findings the lender’s risk consultant flags during a compliance audit.
- Auto liability $1M combined single limit minimum, scaled up by trade. Owned, hired, and non-owned autos all covered. Steel erectors, concrete subs, demolition, and any sub running heavy haul or off-road equipment commonly require $2M, with umbrella stacking. Verify “any auto” or the proper combination of owned/hired/non-owned codes is checked, not just “scheduled autos”. Scheduled-only auto coverage is a regular finding on smaller subs operating their personal vehicles for project errands.
- Umbrella or excess coverage scaled to project. Mid-size commercial typically requires $5M umbrella; ground-up institutional and lender-financed work routinely requires $10M, $15M, or $25M. Verify the umbrella sits over the right underlying policies (CGL, Auto, employer’s liability) and that it is truly “follow-form”. Meaning it follows the underlying terms exactly, not narrower. Non-follow-form umbrellas leave gap exposure that the lender’s risk consultant will flag immediately.
- Workers compensation statutory plus $1M employers liability, multi-state where applicable. Statutory WC limits vary by state and are non-negotiable. Employers Liability must show $1M per accident / $1M disease per employee / $1M disease policy limit minimum. If the sub is licensed in or pulls labor from multiple states, confirm the policy’s “Other States” coverage covers every state on the project route. Gaps here trigger uninsured-employer exposure that flows back to the GC under most state statutes.
- Builder’s risk verification. Separate policy, not on the ACORD 25. Builder’s risk damage to the work itself is almost never carried on the sub’s CGL. Confirm with the project owner and developer that a project-specific or owner’s-program builder’s risk policy is in force, that the insured schedule includes the GC and all subs as additional named insureds (not just additional insureds), that the deductible allocation matches the subcontract, and that soft-cost / delay-in-completion coverage is in place if the project schedule is the lender’s covenant.
- Pollution liability / contractor’s pollution where scope triggers it. Demolition, excavation, environmental remediation, asbestos abatement, fuel-system trades, paint/coating subs, and any sub disturbing existing soil require contractor’s pollution liability (CPL). The base CGL excludes most pollution exposures. Confirm a CPL policy is in force at the limits the prime contract requires. Typically $1M / $2M minimum, higher on environmentally sensitive sites.
- Professional liability for design-build and design-assist scope. Any sub performing design work, design-build mechanical, design-assist curtainwall, performance-spec’d elevators, or any delegated-design scope, must carry professional liability (architects and engineers E&O). The base CGL excludes professional acts. Confirm the policy is on a project-specific or practice-policy basis with limits scaled to project value, typically $1M / $2M minimum, $5M+ on large or institutional work.
- Cancellation notice meets contract requirement. Most commercial subcontracts require 30 days’ written notice of cancellation directly to the certificate holder. Lender-financed and institutional work commonly require 60 or 90 days. Confirm the certificate’s notice section meets the prime contract’s specific requirement, and that every certificate holder (GC, owner, developer, lender, property manager) is listed in the notice provision, not just the lead GC.
- Policy effective dates align with contract dates and renewal cadence is calendared. Policy expiration before the project’s substantial completion is a routine finding. Confirm every policy on the ACORD 25, CGL, Auto, WC, Umbrella, CPL, Professional, extends through substantial completion plus the completed-operations tail required by contract. Calendar the renewal date for each policy and trigger a renewal-COI request 45 days before expiration so the renewed certificate is in hand before the policy lapses.
How to use the checklist
Run this checklist on every new sub COI before subcontract issuance, and again on every renewal. For each item:
- Mark
- OK, Flag (gap exists, sub can fix), or
- Reject and resubmit (sub must fix and reissue before subcontract issuance or before next pay application).
- Demand the actual endorsement copies for items 4, 5, 6, 7, 8, and 9. Box-checks alone are not coverage. The endorsements attach to a separate folder behind the COI in the project’s compliance binder.
- Anything
- Flag stops mobilization or stops the sub’s first pay application until cleared. Anything
- Reject and resubmit stops subcontract issuance until corrected. Do not allow the sub on site under a deficient certificate.
- File the completed checklist with the sub’s COI in the project’s insurance binder. When the developer’s risk manager, the lender’s compliance consultant, or the owner’s representative asks for proof of coverage, the binder is the answer.
- For lender-financed projects, share the completed checklist with the lender’s risk consultant during draw review. Proactive disclosure shortens draw approval cycles.
Quarterly cadence: re-pull every active sub’s COI and re-run the checklist on each. Subs change carriers mid-project. New carrier, new ratings, new endorsement language. The renewal is rarely a clean copy of the prior cert. On longer commercial projects (12+ months), run the full checklist again at the 6-month mark even if no certificate changed, because new project parties (new lenders, refinanced ownership, new property managers) may have been added to the indemnity schedule and need to be on the certificate as additional insureds.
Stop reviewing COIs by hand.
The 17 line-items above take an experienced commercial risk manager 18 to 22 minutes per certificate. Multiply by 80 active subs across 5 commercial projects and you have built a part-time job out of COI review every Friday, and that is before the renewals, the carrier changes, and the mid-project scope additions that trigger fresh certificates. Contracts Connected’s COI Analyzer reads every ACORD 25 the moment a sub emails it in, automatically pulls the endorsement copies, validates the limits and forms against the subcontract requirements, cross-checks every additional-insured name against the prime contract’s indemnity schedule, and flags any of the 17 items that fail. Before the COI ever lands in your binder.
For educational purposes. These templates, checklists, and trackers are operator-built starting points designed to help you move faster on the kind of work that usually drowns construction admins in email chains. They are not legal, insurance, accounting, or tax advice. Each project, jurisdiction, and contract has its own quirks. Review the document, refine the language, and consult your attorney, broker, CPA, or compliance officer before relying on it for a live project decision.
Frequently asked questions about commercial ACORD 25 review
What is ACORD 25?
ACORD 25 is the industry-standard Certificate of Liability Insurance form, used to prove that a contractor or subcontractor carries the insurance coverage required by their contract. Every COI you receive from a sub will be on this form (or its electronic equivalent). It is published and maintained by ACORD, an insurance industry association. The form structure is consistent across every carrier, which is why a checklist that follows the form’s layout is portable across every sub and every carrier you will ever review.
How do commercial COI requirements differ from federal?
Federal requirements are anchored in the FAR (Federal Acquisition Regulation) and agency supplements, with a single contracting-officer counterparty. Commercial requirements are anchored in the prime contract, which is shaped by the developer, the institutional owner, and the lender. Each of whom adds their own additional-insured names, limit thresholds, cancellation-notice durations, and aggregate-protection requirements. Commercial review is generally more variable from project to project; federal review is generally more uniform but with stricter form-attachment expectations under FAR 28.106.
Is the ACORD 25 itself binding coverage?
No. The certificate is informational only. Coverage is established by the policy and modified by endorsements attached to that policy. The ACORD 25 is evidence that a policy exists with certain features as of a specific date. To verify coverage, you must collect copies of the actual endorsement forms (CG 20 10, CG 20 37, CG 20 33, CG 20 38, CG 24 04, CG 25 03, and the equivalent state-specific WC waiver form) referenced on the certificate. Box-checks alone are not enforceable when a claim hits and a tender is contested.
Who should be listed as certificate holder on a commercial project?
Every party named in the prime contract’s indemnity and additional-insured schedule. On a typical commercial project that means the GC, the owner, the developer, the lender, the property manager, the architect, the engineer of record, and sometimes a building tenant or anchor occupant. Generic listings like “General Contractor” or “Owner” are insufficient. Many cancellation-notice provisions require the carrier to send notice to a named entity at a specific address, and any party not named is a party with no notice right and no tender right.
What if the COI is missing the per-project aggregate (CG 25 03)?
A single large claim on a different project the sub is on can exhaust the entire policy aggregate, leaving you uncovered on yours. The CG 25 03 endorsement reinstates the aggregate per-project, ensuring the limits dedicated to your project are not drained by claims on others. Without CG 25 03, you are effectively sharing limits with every other project the sub is currently on. On commercial work, especially developer-financed or institutional projects, this is a hard rejection. Always demand it before subcontract issuance.
Does the ACORD 25 cover builder’s risk?
No. The CGL on the ACORD 25 does not cover physical damage to the work-in-progress itself. Builder’s risk is a separate policy, almost always carried by the project owner or developer (sometimes by the GC under an owner-controlled program). Confirm with the owner that builder’s risk is in force, that the insured schedule includes the GC and all subs as additional named insureds with proper soft-cost and delay-in-completion endorsements, and that the deductible allocation between owner, GC, and subs is documented in writing before any work that could trigger a claim begins on site.