Auto Liability COI Requirements: The Complete Guide for Insurance Professionals

The auto liability certificate of insurance is the section of ACORD 25 that reports coverage under the named insured's Business Auto Coverage Form (BAP), which is ISO form CA 00 01. The certificate's usefulness depends on how accurately it reports the symbol codes that define which vehicles are covered. Symbol 1 means any auto. Symbol 7 means specifically described autos. Symbols 8 and 9 cover hired and non-owned exposures. The difference between a certificate showing "Symbol 1" and a certificate showing "Symbols 7, 8, 9" has meaningful coverage implications for the party relying on it, yet most brokers issue auto liability certificates without ever explicitly checking which symbols actually appear on the underlying declaration page.

This guide walks through the symbol codes as they appear on the Business Auto Coverage Form, how they translate to the auto liability section of ACORD 25, the limit options (combined single limit vs split limits), hired and non-owned treatment, the difference between commercial auto and business auto, the most common endorsements (CA 20 48, CA 99 33), and state-specific minimums for commercial auto in TX, CA, NY, and FL.

Key Takeaways

• The ISO Business Auto Coverage Form (CA 00 01) uses 10 symbol codes (1, 2, 3, 4, 5, 6, 7, 8, 9, 19) to describe which autos are covered. Symbol 1 is broadest, Symbol 7 is narrowest among scheduled autos.
• Combined single limit (CSL) of $1,000,000 is the most common commercial auto limit. Split limits of $1M per person / $2M per occurrence / $1M property damage are less common but still in use on legacy policies.
• Hired and non-owned auto coverage requires Symbols 8 and 9 (not Symbol 1 alone). Some policies write hired and non-owned as a separate endorsement for insureds with no owned autos.
• "Commercial auto" and "business auto" are the same line of coverage; "truckers" and "motor carrier" are distinct lines with different forms (ISO CA 00 12 for truckers, the Motor Carrier Coverage Form CA 00 20).
• State commercial auto minimums: Texas $300,000 combined single limit; California $15/$30/$5 (personal) and $750,000 for commercial vehicles; New York $25/$50/$10 (personal) with higher limits for commercial motor carriers; Florida $10,000 PDL plus $10,000 PIP with commercial minimums varying by vehicle type.
• BrokerageAudit's COI Manager reads symbol codes on the BAP declaration and flags certificates that misrepresent symbol coverage.

The Auto Liability Section of ACORD 25

On the current ACORD 25 (2016/03) form, the auto liability section occupies the second row of the Coverages grid. The section reports:

• The type of auto liability coverage (Combined Single Limit or Split Limits)
• Whether Additional Insured is indicated (checkbox)
• Whether Subrogation is Waived (checkbox)
• Policy number
• Policy effective date and expiration date
• Limit amounts by category

The type of coverage box includes options labeled "Any Auto," "Owned Autos Only," "Scheduled Autos," "Hired Autos Only," and "Non-Owned Autos Only." These map directly to the symbol codes on the BAP declaration.

The limits box reports up to four values: combined single limit or (if split limits) bodily injury per person, bodily injury per accident, and property damage per accident. Some BAPs separate medical payments and uninsured/underinsured motorist, which appear on the policy declaration but may or may not appear on the certificate depending on carrier practice.

Accurate certificate reporting requires the producer to match each checkbox and limit to the underlying BAP declaration. The most common error is checking "Any Auto" on the certificate when the underlying policy uses specifically described autos (Symbols 7, 8, 9).

The BAP Symbol Codes: What They Actually Mean

The Business Auto Coverage Form uses numbered symbols in the declaration to indicate which autos are covered for each coverage line. The symbols run from 1 through 9 plus 19 for most policies.

The symbols appear on the BAP declaration page in a grid that shows which coverages (Liability, Uninsured Motorist, Medical Payments, Physical Damage - complete, Physical Damage - Collision) apply to which symbols. A policy might show:

• Liability: Symbols 1
• Uninsured Motorist: Symbol 2
• Physical Damage: Symbol 7

This pattern is common on large fleet accounts where the insured wants the broadest liability protection (Symbol 1) but narrower scope for physical damage (only specifically listed vehicles).

On the certificate, the checkbox selection should reflect the liability symbol. Symbol 1 corresponds to "Any Auto." Symbols 2 and 7 correspond to "Owned Autos Only" or "Scheduled Autos." Symbols 8 and 9 correspond to "Hired Autos" and "Non-Owned Autos."

The Symbol 1 vs Symbol 7+8+9 Debate

Two ways to write business auto coverage that looks similar on the surface but differs substantively:

Symbol 1 (Any Auto). Covers all autos: owned, leased, rented, borrowed, and employee vehicles used in the business. Premium is calculated based on owned-auto count plus a factor for non-owned and hired exposures. The certificate shows "Any Auto" checked.

Symbols 7, 8, 9 (Specifically Described, Hired, Non-Owned). Symbol 7 covers only the vehicles listed on the declaration. Symbol 8 covers hired autos. Symbol 9 covers non-owned autos. The combination replicates most of what Symbol 1 provides at potentially lower premium because it excludes certain categories (future-acquired autos without notification, for instance).

The key differences:

• New autos acquired during the policy term. Symbol 1 covers automatically. Symbol 7 requires reporting within a specified period (typically 30 days).
• Temporary substitute autos. Both Symbol 1 and Symbol 7 cover temporary substitutes but the definitions vary.
• Trailers. Both typically cover owned trailers. Rented and borrowed trailers may require Symbol 8.
• Autos used by employees with owner's permission. Symbol 1 covers. Symbols 7+8+9 may have gaps depending on employee ownership of the auto.

For large fleet accounts, Symbol 1 simplifies administration and provides the broadest coverage. For smaller accounts with stable vehicle counts, Symbols 7+8+9 may offer similar coverage at lower cost.

Contract requirements sometimes specify the symbol. Government contracts and large master service agreements increasingly require "Symbol 1 - Any Auto" to verify the broadest possible coverage. Brokers should check contract language and confirm the policy symbols match.

Limits: $1M CSL vs $1M/$2M Split Limits

Commercial auto liability limits come in two formats: combined single limit (CSL) and split limits.

Combined single limit. A single limit that applies to all bodily injury, property damage, and medical expenses arising from one accident. A $1,000,000 CSL means the carrier will pay up to $1M total for any covered accident, regardless of how many people are injured or how the damages are distributed between bodily injury and property damage.

Split limits. Separate limits for bodily injury per person, bodily injury per accident, and property damage per accident. A $1,000,000 / $2,000,000 / $1,000,000 split limit means up to $1M per person for bodily injury, up to $2M total for bodily injury in one accident (multiple people), and up to $1M for property damage.

Combined single limit is the dominant structure in commercial auto today. Most carriers default to CSL for accounts above minimum premium thresholds. Split limits persist on some legacy policies and on smaller commercial auto accounts where the carrier's filed rates support split limits more cheaply.

Common limit amounts in 2026.

On the certificate, the combined single limit appears in a single cell. Split limits appear in three cells. Agencies sometimes make errors when converting between formats during certificate issuance, particularly when the underlying policy is split limits and the contract requires CSL.

Hired and Non-Owned on the Certificate

Hired and non-owned auto coverage deserves separate attention because it protects the insured for vehicles they do not own but that create business liability.

Hired auto (Symbol 8). Covers vehicles rented, leased, or borrowed by the named insured for business use. Example: an employee rents a car for a business trip; the named insured has hired auto coverage that responds.

Non-owned auto (Symbol 9). Covers vehicles not owned, rented, leased, or borrowed by the named insured but used in business operations. Example: an employee uses their personal car to drive to a client meeting; the named insured has non-owned auto coverage that provides excess coverage over the employee's personal policy.

For insureds with no owned autos but some business vehicle exposure (a consulting firm where employees occasionally drive for business), hired and non-owned is often written as a separate endorsement on a package policy or general liability policy rather than as a standalone BAP.

The certificate should reflect the actual coverage. A certificate showing "Any Auto" when the policy has only hired and non-owned coverage misrepresents the coverage. A certificate showing only "Hired" when the policy covers both hired and non-owned understates coverage.

Employers' Non-Ownership Liability (ENOL) is a specific coverage extension on BAPs that protects employers when employees use their personal vehicles for business. CA 99 33 is the most common ENOL endorsement. If the certificate holder (often a customer or contract counterparty) requires ENOL coverage, verify that CA 99 33 is on the policy.

Commercial Auto vs Business Auto

The terms "commercial auto" and "business auto" are often used interchangeably but have subtle distinctions in the industry.

Business Auto Coverage Form (CA 00 01). The ISO form for most commercial auto accounts. Covers owned, hired, non-owned, and leased vehicles for business use. Private passenger and commercial vehicles are both written on this form.

Truckers Coverage Form (CA 00 12). A specialized form for motor carriers and trucking companies. Covers the unique exposures of interstate trucking: cargo liability, motor carrier filings (MCS-90), and specialized physical damage coverage.

Motor Carrier Coverage Form (CA 00 20). Another specialized form for motor carriers, sometimes used in place of or alongside CA 00 12.

Public Auto Coverage Form (CA 00 05). Used for public transportation (taxis, buses, ride-sharing at commercial scale).

"Commercial auto" is the umbrella term that includes all of these. "Business auto" typically refers specifically to CA 00 01.

Certificate holders sometimes require "commercial auto" coverage without specifying the form. The broker should confirm which specific form is on the policy and verify the coverage is adequate for the contract exposure. A consulting firm with CA 00 01 business auto does not satisfy a contract requiring motor carrier coverage.

Common Auto Endorsements: CA 20 48 and CA 99 33

Two auto endorsements show up frequently on commercial auto certificates and deserve understanding.

CA 20 48 (Designated Insured for Covered Autos). Adds a specific party as insured with respect to the covered autos. This is the auto-liability equivalent of a CG 20 10 or CG 20 37 additional insured endorsement. Common when a contract requires additional insured status on the auto liability coverage. The designated insured is covered for liability arising from the named insured's operation of the covered autos.

CA 99 33 (Employees as Insureds / Employee Hired Autos / various editions). Has multiple variants with the same CA 99 33 designation but different coverage extensions. The most common version extends insurance to employees for autos they hire and use in business operations. This is important when employees rent cars and the named insured wants to extend its auto liability policy to those vehicles.

Other common endorsements:

• CA 99 44 (Drive Other Car Coverage). Extends non-owned auto coverage to specified individuals (typically executives or key employees).
• CA 23 92 (Lessor - Additional Insured and Loss Payee). Adds a leasing company as both additional insured and loss payee on vehicles leased from them.
• CA 20 54 (Additional Insured - Lessor). An alternative form for adding a lessor as additional insured.

On the certificate, these endorsements are typically noted in the description of operations field or reflected in the Additional Insured checkbox (for CA 20 48) and Loss Payee notation (for CA 23 92).

See our related coverage of certificate holder requirements and the certificate of property insurance companion form.

State-Specific Minimums for Commercial Auto

State laws set minimum auto liability limits. For commercial auto, these minimums often differ from personal auto minimums and vary by vehicle type.

Texas. Tex. Transp. Code 601.072 and 601.076. Personal auto minimums: $30,000 per person bodily injury, $60,000 per accident bodily injury, $25,000 property damage ($30/$60/$25). Commercial motor carriers (TxDOT registered): $500,000 combined single limit for intrastate, up to $1,000,000 for certain hazardous operations. Commercial vehicles under 26,001 pounds: $300,000 CSL typical baseline.

California. CA Ins. Code 11580.1b for personal. Personal auto minimums: $15,000 per person bodily injury, $30,000 per accident bodily injury, $5,000 property damage ($15/$30/$5). Commercial vehicles over 10,000 pounds: $750,000 CSL. Commercial passenger vehicles (shuttles, limos): varies by passenger count, up to $5,000,000 for larger vehicles.

New York. NY Veh. & Traf. Law 311. Personal auto minimums: $25,000 per person bodily injury, $50,000 per accident bodily injury, $10,000 property damage ($25/$50/$10), plus $50,000 per person / $100,000 per accident for death. Commercial motor carriers (NYS DOT): $750,000 to $5,000,000 CSL depending on vehicle weight and operation type.

Florida. Fla. Stat. 627.7275 and 627.733. Personal auto minimums: $10,000 PDL (property damage liability), $10,000 PIP (personal injury protection). Florida does not require personal bodily injury liability as a statutory minimum, though most financial responsibility requirements trigger $10/$20 BI. Commercial vehicles: $50,000 to $300,000 depending on weight and operation type.

State minimums are floors. Most contracts require significantly higher limits. Federal Motor Carrier Safety Regulations (FMCSR) impose minimum financial responsibility requirements on interstate motor carriers: $750,000 for general freight, $1,000,000 for passenger vehicles under 15 seats, $5,000,000 for larger passenger vehicles or hazardous materials.

When issuing a certificate, verify that the policy limits meet both (a) the state statutory minimums in every state where the named insured operates, and (b) the contract-specified minimums for each certificate holder.

Common Certificate Errors on Auto Liability

Four recurring errors dominate E&O claims on auto liability certificates.

Checking "Any Auto" when the policy uses Symbol 7. The certificate implies broader coverage than the policy provides. A claim involving a non-scheduled vehicle reveals the gap.

Misreporting hired and non-owned. The certificate shows both hired and non-owned, but the policy has only hired. A claim involving an employee's personal vehicle reveals no coverage exists.

Wrong limit format. The policy has split limits of $1M/$2M/$1M but the certificate reports $1M CSL. The $2M total bodily injury on split limits is higher than the $1M CSL, but certificate holders relying on CSL for aggregate exposure are misled.

Missing or incorrect additional insured form reference. The contract specifies CA 20 48 for auto liability additional insured. The policy has no CA 20 48 endorsement. The certificate shows "Additional Insured" checked. The certificate holder relies on the representation, and when a claim hits, the carrier denies because no endorsement exists.

Each of these errors is catchable by reviewing the BAP declaration page against the certificate. BrokerageAudit's COI Manager does this automatically.

Using BrokerageAudit for Auto Liability Certificate Management

The COI Manager reads the BAP declaration, identifies the active symbol codes, confirms limit formats, and maps the policy endorsements (CA 20 48, CA 99 33, CA 23 92) to certificate representations.

For each certificate, the system flags the four common errors above before issuance. For incoming certificates from vendors or contractors, the system runs verification checks that confirm the auto liability coverage actually matches what the certificate claims.

For fleet accounts with vehicle additions and removals during the policy term, the system also tracks whether the policy's symbol configuration supports automatic coverage for newly-acquired vehicles. Symbol 7 policies require notice of new acquisitions within carrier-specified windows.

See also our certificate holder analysis and the auto liability endorsement guide.

Frequently Asked Questions

What are the standard auto liability COI requirements?

Standard commercial auto liability certificate requirements typically include: combined single limit of $1,000,000 (the most common limit in US commercial contracts), "Any Auto" symbol coverage or the equivalent of Symbols 1 or 7+8+9, specific additional insured endorsement (CA 20 48 or similar) when the contract requires it, waiver of subrogation when required, and primary and non-contributory treatment when specified. Higher-risk operations (hazardous materials, interstate trucking, large passenger vehicles) require higher limits per Federal Motor Carrier Safety Regulations, up to $5,000,000.

What are the typical auto liability limits ($1M CSL vs $1M/$2M split limits)?

The $1,000,000 combined single limit (CSL) is the most common structure in US commercial contracts. CSL means a single limit applies to all bodily injury and property damage from one accident. Split limits separate the limits: $1,000,000 per person bodily injury, $2,000,000 per accident bodily injury, $1,000,000 property damage (often written as $1M/$2M/$1M). Split limits are less common today but still appear on legacy policies. Carriers often convert split-limit policies to CSL at renewal because CSL is simpler to administer.

How is hired and non-owned auto coverage shown on a COI?

Hired and non-owned coverage appears in the auto liability section of ACORD 25 through checkboxes labeled "Hired Autos Only" and "Non-Owned Autos Only." These correspond to Symbols 8 (hired) and 9 (non-owned) on the underlying Business Auto Coverage Form. A policy with Symbol 1 (Any Auto) automatically includes hired and non-owned. A policy with Symbols 7+8+9 covers specifically described autos plus hired plus non-owned. A certificate should check both hired and non-owned boxes when the policy actually covers both, and only one when it covers only one.

What is the difference between commercial auto and business auto?

"Business auto" typically refers to the ISO Business Auto Coverage Form (CA 00 01), which is the standard form for most US commercial auto policies. "Commercial auto" is the broader umbrella term that includes business auto plus specialized forms: Truckers Coverage Form (CA 00 12) for motor carriers, Motor Carrier Coverage Form (CA 00 20) for interstate trucking, and Public Auto Coverage Form (CA 00 05) for taxis, shuttles, and buses. Certificates should identify the specific form on the underlying policy, especially when the certificate holder's contract requires a specific form (such as motor carrier coverage for freight operations).

What do the symbol codes on an ACORD 25 certificate mean?

ISO BAP symbol codes define which autos are covered for each coverage line. Symbol 1 is Any Auto (broadest). Symbol 2 is Owned Autos Only. Symbol 3 is Owned Private Passenger Autos. Symbol 4 is Owned Autos Other Than Private Passenger. Symbol 5 is Owned Autos Subject to No-Fault. Symbol 6 is Owned Autos Subject to Compulsory UM. Symbol 7 is Specifically Described Autos. Symbol 8 is Hired Autos Only. Symbol 9 is Non-Owned Autos Only. Symbol 19 is Mobile Equipment Subject to Compulsory Auto. On ACORD 25, the checkboxes (Any Auto, Owned Autos Only, Scheduled Autos, Hired Autos Only, Non-Owned Autos Only) map to these symbols.

What are the most common auto endorsements (CA 20 48, CA 99 33)?

CA 20 48 (Designated Insured for Covered Autos) adds a specific third party as additional insured for claims arising from the named insured's operation of covered autos. It is the auto-liability analogue of CG 20 10 on general liability. CA 99 33 (Employees as Insureds / Employee Hired Autos) has multiple variants; the most common version extends coverage to employees for autos they hire and use in business. Other common endorsements include CA 99 44 (Drive Other Car Coverage for specified individuals), CA 23 92 (Lessor Additional Insured and Loss Payee), and CA 20 54 (Additional Insured - Lessor). Each appears in the policy declaration or endorsement schedule and should be verified against certificate representations.

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

Verify every auto liability certificate against the BAP declaration. BrokerageAudit's COI Manager reads symbol codes on the Business Auto Coverage Form, maps them to certificate representations, and flags the four most common auto certificate errors before issuance. Explore COI Manager