The 12 line-items every federal prime must verify on every subcontractor’s ACORD 25, including the federal-only endorsements, limit thresholds, and Miller Act coordinations the generic insurtech guides skip.
Why federal primes need an ACORD 25 review checklist that goes beyond box-checks
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 something goes wrong on the project. On a federal-construction job, 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 prime.
Every federal contracting officer eventually finds the same problem during a project audit: the prime 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. Under FAR 28.106 and the prime’s Miller Act bond coordination, the prime carries the consequences of that gap, not the sub.
What makes a federal review different from a commercial review:
- Higher limits. Federal CGL minimums commonly run $1M per occurrence / $2M aggregate, with $5M umbrella stacks. State and commercial work often accepts lower.
- Per-project aggregate is mandatory. A single large claim on one project can otherwise exhaust the policy aggregate across every project the sub is on, leaving the prime exposed on others. The CG 25 03 endorsement reinstates the aggregate per-project. Generic insurtech guides routinely skip this.
- A.M. Best rating verification. Most federal primes require carriers rated A- or better; some require A or A+. The certificate must show the rating.
- Miller Act coordination. On federal projects over $150K, payment and performance bonds attach. The COI doesn’t replace the bond, but the bond claimants’ rights interact with the CGL’s additional-insured language.
- Statutory cancellation notice. Federal subcontracts typically require 30 days’ written notice of cancellation directly to the prime as certificate holder, by name and project number, not the agency.
This checklist is the practitioner’s version. It’s the artifact a federal-prime risk manager actually uses on every weekly COI review pass to flag the gaps that turn into withheld payments. Run it on every sub’s certificate before the project mobilizes. Re-run it on every renewal cycle. Keep the completed checklist alongside each sub’s COI in the project file.
Who this checklist is for
- Federal general contractors managing 50–500+ subcontractor COIs per active project
- Prime contractors required to verify and retain sub-COIs under FAR 28.106 and Miller Act provisions
- Risk managers and compliance officers running weekly COI review passes
- Project administrators chasing late COIs and renewals
- Insurance brokers on the prime’s side advising on flow-down requirements
If you’re a sub trying to issue a clean COI to your prime, you want our ACORD 25 review checklist (commercial) instead. It’s the same form-by-form review at lower limits.
The 12-line-item federal ACORD 25 review
The checklist covers 12 things every prime must verify on every federal-project ACORD 25. In the order an experienced risk manager works through the certificate:
- Producer and insurer A.M. Best rating verification. The certificate names a Producer (broker) and one or more Insurers. Verify the carrier’s A.M. Best rating directly at ambest.com. Most federal primes require A- or better, some require A or A+. A B+ carrier on a federal project is a common 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 and parent-subsidiary mismatches generate the most preventable coverage disputes.
- CGL limits. $1M occurrence / $2M aggregate minimum. Federal-prime baseline. Higher-risk trades (electrical, structural steel, demolition) commonly require $2M / $4M. Confirm the limits column on the ACORD 25 matches what your subcontract requires; “matching” includes products-completed-operations aggregate as a separate line.
- 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 project can exhaust the aggregate before yours pays out. Demand a copy of the endorsement, not just the box-check.
- Additional insured ongoing ops (CG 20 10) confirmed. This endorsement extends coverage to the prime for liability arising out of the sub’s ongoing operations. The endorsement form number and edition date must be on the certificate’s Description of Operations section, AND a copy of the actual endorsement must be on file. Box-check is not enough.
- Additional insured completed ops (CG 20 37) confirmed. Companion endorsement to CG 20 10, covering liability after the sub’s work is completed. Federal projects often have completed-ops tails of 5+ years; 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’s a finding.
- Waiver of subrogation (CG 24 04) on CGL and WC. The waiver prevents the sub’s insurer from later suing the prime 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). Both must be confirmed.
- Primary and non-contributory wording explicit on CGL. Without “primary and non-contributory” language, the prime’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.
- Auto liability $1M combined single limit minimum. Owned, hired, and non-owned autos all covered. Higher limits ($2M) common when the sub has fleet or off-road equipment in scope. Verify “any auto” or the proper combination of owned/hired/non-owned codes is checked, not just “scheduled autos.”
- Umbrella or excess $5M follow-form over CGL/Auto/WC. Federal primes often require $5M minimum umbrella; large projects $10M+. Verify the umbrella sits over the right underlying policies (CGL, Auto, employer’s liability) and that it’s truly “follow-form”. Meaning it follows the underlying terms exactly, not narrower. Non-follow-form umbrellas leave gap exposure.
- Workers comp statutory plus $1M employers liability. Statutory WC limits vary by state and are non-negotiable. The Employers Liability section must show $1M per accident / $1M disease per employee / $1M disease policy limit minimum. USL&H is required when work is over navigable waters; Jones Act when work is on a vessel.
- Cancellation notice 30 days written, certificate holder named correctly. Federal subcontracts typically require the carrier to provide 30 days’ written notice of cancellation directly to the prime as certificate holder, by name and project number. Confirm the certificate holder section reads exactly as your subcontract requires, not “Project Owner” or a generic legal entity name. The agency is rarely the certificate holder; the prime is.
How to run the checklist on every sub’s COI
Run this checklist on every new sub COI before mobilization, and again on every renewal. For each item:
- Mark
- OK, Flag (gap exists), or
- Reject and resubmit (sub must fix and reissue).
- Demand the actual endorsement copies for items 4, 5, 6, 7, and 8. Box-checks alone are not coverage. The endorsements attach to a separate folder behind the COI.
- Anything
- Flag stops mobilization until cleared. Anything
- Reject and resubmit stops sub payment until corrected.
- File the completed checklist with the sub’s COI in the project’s insurance binder. When the contracting officer asks for proof of coverage, the binder is the answer.
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 isn’t always a clean copy of the prior cert.
Stop reviewing COIs by hand
The 12 line-items above take an experienced risk manager 15 minutes per certificate. Multiply by 50 active subs across 4 federal projects and you’ve built a part-time job out of COI review every Friday. 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, and flags any of the 12 items that fail. Before the COI ever lands in your binder. Same checklist, runs itself, on every cert from every sub on every project.
Frequently asked questions about federal 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’s published and maintained by ACORD, an insurance industry association. The form structure is consistent across every carrier.
Why are federal CGL limits higher than commercial?
Federal primes carry stricter flow-down requirements and larger umbrella stacks because federal contracts under FAR 28.106 require the prime to verify sub coverage adequacy, and the Miller Act payment and performance bonds amplify the prime’s exposure to sub-tier failures. Commercial primes can negotiate lower limits with owners; federal primes generally cannot. The agency’s contract sets the floor and the prime can only require equal or higher of subs.
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 24 04, CG 25 03, etc.) referenced on the certificate. Box-checks alone are not enforceable.
What endorsements should I demand copies of, not just see checked?
Always demand the actual endorsement forms for: CG 20 10 (Additional Insured, Ongoing Operations), CG 20 37 (Additional Insured, Completed Operations), CG 24 04 (Waiver of Subrogation, CGL), CG 25 03 (Per-Project Aggregate), and the equivalent state-specific WC waiver-of-subrogation form. The certificate confirms these are in place; the endorsement copies prove it. Risk managers who only check the boxes are setting themselves up for a coverage dispute.
Who should be listed as certificate holder on a federal project?
The prime contractor’s exact legal entity, including the project number and project address when possible. 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. The agency owning the federal contract is rarely the certificate holder; the prime is, because the prime is the entity managing the sub relationship.
What happens if a sub’s 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 aren’t drained by claims on others. Without CG 25 03, you’re effectively sharing limits with every other project the sub is currently on. Always demand it on federal work and most large commercial work.