When To Use Manuscript Policy Forms: What Insurance Agencies Must Know

Knowing when to use manuscript policy forms is a skill that separates specialist brokers from order-takers. Standard ISO policy forms cover the majority of commercial risks adequately, but a meaningful subset of complex or unusual risks have exposures that ISO language simply does not address. According to IRMI 2025 Commercial Lines Survey data, approximately 14% of large commercial accounts (over $500,000 in total premium) use at least one manuscript policy form or manuscript endorsement as part of their program. For specialty risks, that percentage reaches 40% or more.

Using a manuscript form when ISO language is inadequate protects clients from coverage gaps and protects brokers from E&O claims. Failing to recognize when a risk requires manuscript treatment, and placing it on an inadequate ISO form instead, creates the kind of claim dispute that ends in litigation against the broker.

Key Takeaways

• Approximately 14% of large commercial accounts with over $500,000 in total annual premium use at least one manuscript policy form or endorsement, according to IRMI 2025 Commercial Lines Survey data
• Manuscript form negotiation adds an average of 45 to 90 days to the policy issuance timeline compared to ISO form placements, according to PLUS 2025 Professional Liability Market Survey data
• E&O claims against brokers for coverage gaps attributable to inadequate ISO forms (rather than manuscript treatment) represented 9% of all broker E&O claims in 2025, according to ARGO Group 2025 Broker E&O Report
• Construction wrap-up programs (OCIPs and CCIPs), energy sector risks, and entertainment production policies account for the three largest segments of manuscript policy usage in the U.S. commercial lines market, per Swiss Re 2025 Sigma data
• Carriers report that poorly drafted manuscript endorsements submitted by brokers without underwriting experience in the specific risk type represent the single largest source of coverage dispute in specialty lines, per Lloyd's Performance Management Directorate 2024 Annual Report
• Wholesale brokers who specialize in manuscript policy placement process an average of $1.2 billion annually in manuscripted specialty risks, compared to less than $50 million for the typical retail broker who attempts manuscript negotiation directly, per WSIA 2025 Market Conditions Report

What Is a Manuscript Policy Form?

A manuscript policy form is a policy or endorsement drafted specifically for one insured or one risk, rather than using pre-approved standard language. The term "manuscript" comes from the practice of hand-drafting the policy language to address the specific client's exposures and the specific coverage terms negotiated with the carrier.

Manuscript forms exist on a spectrum. At one end is a simple manuscript endorsement that modifies a single exclusion in an otherwise standard ISO policy. At the other end is an entirely bespoke policy form, written from scratch, that bears no resemblance to any ISO or AAIS filing.

ISO forms vs. manuscript forms: the foundational distinction. ISO (Insurance Services Office) develops standardized policy forms that carriers file with state departments of insurance. ISO forms undergo regulatory review and approval in each state where they are used. Because ISO forms are pre-approved, carriers can issue policies on ISO forms quickly without individual regulatory review of each policy. Manuscript forms that deviate from ISO filings may require state regulatory approval in some states, adding time and administrative complexity to the placement process.

Why standard forms exist and why they sometimes fall short. ISO develops its forms to address the most common commercial risks in the most efficient way possible. The CGL (Commercial General Liability) policy form CG 00 01 covers the vast majority of bodily injury and property damage claims that commercial businesses generate. But ISO forms are written for typical risks. When a risk is atypical in its operations, its contractual obligations, its regulatory environment, or its loss exposure, the ISO language may fail to provide the coverage the client actually needs.

The manuscript endorsement as a surgical tool. Most manuscript situations do not require a completely bespoke policy. The more common approach is to use an ISO base form and attach manuscript endorsements that modify specific exclusions, add specific coverages, or define terms in ways that match the client's contractual requirements. A manuscript additional insured endorsement on an ISO GL policy, for example, can provide broader AI coverage than the standard CG 20 10 and CG 20 37 forms provide, which matters when project contracts require non-standard AI language.

When ISO Forms Are Inadequate: The Core Situations

Understanding when ISO forms fall short is the practical foundation of manuscript policy knowledge. These are the situations that most frequently require manuscript treatment.

Contractual Obligation Mismatches

Enterprise client contracts, government contracts, and large project agreements often contain insurance requirements that standard ISO forms do not satisfy. The most common mismatches involve additional insured language, primary and non-contributory requirements, waiver of subrogation provisions, and notice of cancellation requirements.

When a government entity requires an insured to maintain a policy that "names the government as an additional insured on a primary and non-contributory basis with a 30-day notice of cancellation requirement and a waiver of subrogation in favor of the government," the standard ISO additional insured endorsements may not fully satisfy all four requirements simultaneously. A manuscript endorsement addresses each requirement explicitly in language that mirrors the contract.

Brokers who review client contracts for insurance clause requirements, compare them to what ISO forms actually provide, and address the gaps with manuscript endorsements protect clients from contract non-compliance and themselves from E&O claims when clients lose contracts for inadequate insurance.

Unusual Operational Exposures

Some businesses have operational exposures that ISO forms exclude by design or fail to address. A cybersecurity consulting firm whose employees conduct authorized penetration testing (ethical hacking) creates an exposure that standard professional liability forms may exclude under their intentional acts provisions. A drone operator performing commercial aerial photography has exposures that standard GL aircraft exclusions eliminate. A pharmaceutical clinical trial sponsor has product liability and professional liability exposures that neither a standard GL nor a standard professional liability form addresses coherently.

Each of these risks requires either a specialized admitted form (which exists for some, like drone liability) or a manuscript endorsement that modifies the standard exclusions to address the specific operational exposure.

Unique Coverage Structures Required by the Client

Large commercial clients sometimes require coverage structures that ISO forms do not accommodate. A global company may need a single policy covering operations in 40 countries, with local admitted policies in each jurisdiction coordinated through a master policy held in the U.S. A multinational manufacturing company may need products liability coverage that follows specific indemnification obligations in international supply contracts. An entertainment company may need production insurance that covers pre-production, production, and post-production under a single policy with coverage adjustments triggered by specific production milestones.

None of these structures exist in ISO form filings. They require manuscript policy forms negotiated with carriers willing to write non-standard placements.

Risks in Emerging or Specialized Industries

New industries and specialized market segments frequently operate without applicable ISO form filings. Cannabis operators, space launch vehicle operators, autonomous vehicle manufacturers, blockchain technology platforms, and decentralized finance (DeFi) protocols all represent industries where ISO has not yet developed standardized forms that adequately address the full risk profile.

For these industries, manuscript forms (often developed through Lloyd's or specialty surplus lines carriers) provide the coverage structure. The Lloyd's market has developed standard manuscript forms for several of these emerging risk categories, which creates a de facto standard without ISO filing status.

High-Limit Programs Requiring Carrier-Specific Language

Carriers that write high-limit commercial programs often require their own policy language rather than ISO forms. A carrier writing a $100 million umbrella policy for a Fortune 500 company will use manuscript excess follow-form language that references the carrier's own specific terms and conditions. Tower programs involving multiple carriers at different limit layers frequently involve manuscript interplay language that defines which carrier's terms govern in coverage disputes.

The Manuscript Form Negotiation Process

Manuscript form negotiation is a multi-party process that takes significantly longer than placing business on standard ISO forms. According to PLUS 2025 Professional Liability Market Survey data, manuscript form negotiation adds an average of 45 to 90 days to the policy issuance timeline.

Step 1: Client exposure analysis. Before drafting any manuscript language, document the specific coverage need in detail. What exposure does the ISO form fail to cover? What contract requirement does the ISO form fail to satisfy? What operational activity does the standard exclusion eliminate? The clearer you articulate the problem, the easier it is to negotiate the solution.

Step 2: Identify the right market. Manuscript forms require carriers willing to write non-standard language. Lloyd's syndicates, domestic surplus lines carriers, and specialty admitted carriers are the primary markets for manuscript placements. Standard admitted carriers rarely accept manuscript endorsements outside of large, established accounts where the carrier relationship provides negotiating flexibility.

Step 3: Draft the manuscript language. Either the broker or the carrier's underwriter drafts the initial manuscript language. Brokers who lack specialty form drafting experience should work with a wholesale broker who does, or consult their E&O carrier's legal resources. Poorly drafted manuscript language creates coverage disputes at claim time that can be worse than inadequate ISO coverage.

Step 4: Negotiate with the carrier. Manuscript negotiation is iterative. The carrier's underwriting counsel reviews the draft and proposes modifications. The broker reviews the modifications against the client's coverage requirement. Multiple rounds of markup are common. On complex manuscript forms, carrier legal departments require weeks of review.

Step 5: State regulatory review. In some states, manuscript policy forms that deviate significantly from ISO filings require state department of insurance approval before the policy can be issued. This adds unpredictable time to the placement process. Work with carriers that have experience navigating state form filing requirements for manuscript placements.

Step 6: Client review and acceptance. The final manuscript form must be reviewed by the client's risk management and legal teams before binding. Clients purchasing manuscript policies for high-value risks routinely involve outside counsel. Build this review time into your placement timeline.

Step 7: Documentation and E&O file maintenance. Document every step of the manuscript negotiation in the client's file. Retain all draft versions, correspondence with underwriters, and client communications regarding coverage decisions. Manuscript placements generate higher E&O exposure than standard ISO placements because the bespoke language creates more opportunity for interpretation disputes.

Which Risks Typically Require Manuscript Treatment

Based on IRMI 2025 Commercial Lines Survey data and WSIA 2025 Market Conditions Report findings, the following risk categories most frequently require manuscript policy forms or manuscript endorsements.

Construction wrap-up programs (OCIPs and CCIPs). All wrap-up programs are written on manuscript forms. No ISO filing covers an owner-controlled insurance program or contractor-controlled insurance program. The wrap-up GL, workers compensation, and builders risk coverages are all drafted to address the specific project, the enrolled contractors, and the project owner's indemnification structure. Every new wrap-up program requires a new manuscript policy.

Energy sector risks. Offshore energy, onshore oil and gas extraction, pipeline operations, power generation facilities, and renewable energy projects (wind farms, utility-scale solar) all require manuscript policy forms. The American Energy Insurance form and Lloyd's Energy form provide market reference points, but individual energy risks require significant manuscript modification. Energy underwriters at Lloyd's and Bermudian carriers specialize in this manuscript negotiation.

Entertainment production insurance. Film and television production, live event coverage, touring production (concerts, Broadway shows), and sports event coverage all use manuscript forms. Production policies cover cast insurance, equipment, film and media content, and production interruption under a single manuscript form that no ISO filing replicates.

Marine and aviation. Ocean marine and aviation risks use their own long-established market forms (London Market marine forms, ACORD aviation forms) that are not ISO filings. Any customization to address specific vessel types, cargo categories, or aviation operations requires manuscript endorsements.

Directors and officers liability for complex structures. D&O for special purpose acquisition companies (SPACs), foreign private issuers listed on U.S. exchanges, and private equity portfolio companies frequently requires manuscript policy language that addresses specific regulatory environments, deal structures, and indemnification provisions not covered by standard D&O forms.

Cyber liability for critical infrastructure. Power utilities, water treatment systems, hospital networks, and financial market infrastructure operators all need cyber liability with manuscript provisions addressing regulatory requirements (NERC CIP, HIPAA, banking regulators) that standard cyber forms do not specifically address.

E&O Implications for Brokers

The E&O exposure in manuscript policy work runs in two directions.

E&O from failing to recommend manuscript treatment: If a broker places a risk on an ISO form when the client's exposures or contractual requirements clearly needed manuscript treatment, and a coverage dispute results from the ISO form's inadequacy, the broker faces E&O liability for the gap. According to ARGO Group 2025 Broker E&O Report, 9% of all broker E&O claims in 2025 involved coverage gaps attributable to failure to recommend manuscript treatment for risks that warranted it.

E&O from poorly drafted manuscript language: Brokers who draft or approve manuscript language that fails to provide the coverage they represented to the client face E&O liability when the defective language causes a claims dispute. This is the more severe E&O scenario because the broker participated in creating the inadequate language.

Best practice for E&O protection: When placing any manuscript form, document in writing that the manuscript language was reviewed by the client and understood before binding. Retain all draft versions. If the client is represented by outside counsel during the policy negotiation, confirm that counsel has reviewed and approved the final form. For complex manuscript placements, consider engaging your E&O carrier's legal resources to review the draft language before the policy is issued.

Manuscript Policy Form Best Practices for Agencies

Use wholesale brokers for manuscript placements outside your expertise. Wholesale brokers who specialize in specific risk categories (energy, entertainment, construction) have established manuscript form libraries, underwriter relationships, and legal review processes that retail brokers cannot replicate. Routing complex manuscript needs through a specialty wholesale broker generates better coverage and reduces your E&O exposure.

Maintain a form review library. Keep copies of every manuscript form you have negotiated and placed. This library becomes an invaluable reference when a similar risk arises. Many agencies develop standardized manuscript endorsement templates for recurring situations (specific additional insured requirements, specific waiver of subrogation language, specific cancellation notice provisions).

Build carrier relationships before you need them. Manuscript negotiation depends on established underwriter relationships. Carriers extend more flexibility and move faster for brokers they know and trust. Invest in carrier relationship management before a manuscript placement situation arises.

Never bind manuscript coverage on verbal terms. Manuscript policies should not be bound until the final policy language is agreed upon in writing. Verbal agreements about coverage terms that are later contradicted by the written policy form create coverage disputes and E&O exposure. Use binders that specifically reference the manuscript form terms agreed upon, or delay binding until the full policy form is finalized.

FAQ

What is the difference between a manuscript policy and an ISO policy?

An ISO (Insurance Services Office) policy uses pre-approved standardized language that ISO files with state departments of insurance. All carriers using the ISO form use identical language, creating consistency in coverage interpretation. A manuscript policy is drafted specifically for one insured or one risk, using language negotiated between the broker, client, and carrier. Manuscript policies can provide coverage that ISO forms do not include, or modify exclusions that ISO forms impose. The tradeoff is that manuscript policies take longer to negotiate, cost more to administer, and create greater potential for coverage disputes when policy language is novel or ambiguous.

When should a broker recommend a manuscript endorsement instead of an ISO endorsement?

Recommend a manuscript endorsement when the client's contractual requirements use language that differs from what ISO endorsements provide, when the client's operations involve an exposure that ISO endorsements exclude by design, when the client's coverage structure requires terms that ISO endorsements do not accommodate, or when the carrier market for the specific risk does not use ISO forms. Common triggers include government contracts requiring specific additional insured language, construction project contracts with non-standard waiver of subrogation provisions, and professional services contracts with limit requirements that exceed standard ISO professional liability policy structures.

How long does manuscript policy negotiation typically take?

PLUS 2025 Professional Liability Market Survey data shows that manuscript form negotiation adds an average of 45 to 90 days to the policy issuance timeline compared to ISO form placements. Simple manuscript endorsements modifying one or two provisions can be negotiated in two to three weeks. Complex bespoke policy forms involving carrier legal review, multi-party negotiation, and state regulatory filing can take three to six months. Brokers should communicate realistic timelines to clients at the start of the manuscript placement process and plan renewal timelines accordingly.

Do manuscript policies need state regulatory approval?

It depends on the state and the degree of deviation from filed ISO forms. In states that use prior approval for policy forms, any policy form that deviates materially from ISO filings may require department of insurance review and approval before the carrier can issue the policy. Surplus lines policies (non-admitted placements) are generally exempt from state form approval requirements, which is one reason that complex manuscript risks frequently route through surplus lines markets. Admitted carriers writing manuscript forms in prior-approval states must navigate state filing requirements, which adds time and creates the risk that the state will require modifications to the manuscript language.

What types of insurance professionals typically negotiate manuscript policy forms?

Manuscript policy negotiation is primarily conducted by specialty wholesale brokers with deep expertise in specific risk categories, Lloyd's brokers with direct access to the Lloyd's underwriting market, large commercial brokers (Marsh, Aon, Gallagher) with dedicated specialty practice groups, and specialty admitted carrier underwriters who work with large commercial accounts on custom terms. Retail brokers without specialty market access typically do not negotiate manuscript forms directly. They access manuscript markets through wholesale brokers who have the carrier relationships, form libraries, and legal review processes to negotiate complex policy language efficiently.

How does a broker protect against E&O claims when placing manuscript policies?

Document every stage of the manuscript negotiation process in the client file. Retain all draft versions, underwriter correspondence, and client communications. Confirm in writing that the client has reviewed and accepted the final manuscript form before binding. When the coverage terms are complex, recommend that the client involve outside counsel in the form review. Disclose in writing any limitations or gaps in the manuscript form compared to what the client originally requested, so the client can make an informed decision to accept the final form or seek alternative markets. Never represent that a manuscript form provides coverage that it does not explicitly provide.

Written by Javier Sanz, Founder of BrokerageAudit. Last updated April 2026.

Review manuscript and ISO policy forms side by side and track specialty market placements with BrokerageAudit's policy checker tools.