COI Compliance Checklist For Contractors: What Insurance Agencies Must Know

A COI compliance checklist for contractors is the set of items a general contractor or project owner verifies on every subcontractor certificate-of-insurance before authorizing work to begin. Each item on the checklist corresponds to a specific contract insurance requirement. A deficiency on any item stops work authorization until corrected.

For insurance agencies managing contractor accounts, understanding this checklist is essential. The agency is on both sides of this process: issuing certificates for subcontractor clients that need to pass GC compliance checks, and helping GC clients verify subcontractor certificates against their subcontract requirements. A certificate that fails the compliance check creates delays, strained client relationships, and potential E&O exposure if the deficiency stems from an agency error.

Key Takeaways

• Standard contractor insurance minimums: GL $1M/$2M, auto liability $1M CSL, WC statutory/EL $500K/$500K/$500K, umbrella $2M+ following form.
• The 10-item compliance checklist covers named insured accuracy, policy period, limits, AI endorsements (CG 20 10 + CG 20 37), primary and non-contributory, waiver of subrogation on GL and WC, auto coverage breadth, WC employee coverage, umbrella follow-form, and work-type exclusions.
• A certificate that fails any of the 10 items should not result in work authorization.
• Commercial auto additional insured coverage for contractors requires endorsement CA 20 48 - the standard ACORD 25 auto section does not grant AI status without this endorsement.
• Agencies managing contractor accounts need to verify compliance against each GC's or project owner's specific requirements, which vary by contract.

Standard Minimum Insurance Requirements for Contractors

Before running the compliance checklist, the agency and the GC need to know the minimums they are checking against. Standard construction contract minimums in the U.S. market are:

These are floor minimums. Large commercial projects, government contracts, and energy sector work typically carry requirements of 2 to 5 times these amounts. The agency must check the actual subcontract, not assume the standard minimums apply.

The 10-Item COI Compliance Checklist

Item 1: Named Insured Matches the Subcontract

The named insured on the certificate-of-insurance must exactly match the legal entity named in the subcontract. "ABC Construction LLC" is not the same as "ABC Construction Inc." or "ABC Construction." A mismatch raises the question of whether the correct entity is covered. Work through the discrepancy before issuing work authorization - in most cases, the agency can confirm the policy covers the correct entity, but that confirmation needs to be documented.

Item 2: Policy Period Covers the Work Period

Every policy shown on the certificate must have an effective date before the work start date and an expiration date after the anticipated work completion date. If a policy expires mid-project, the GC needs a renewal certificate before expiration. GC compliance systems that automate this check (tracking certificate expiration against project completion dates) catch this before it becomes a problem.

Item 3: GL Limits Meet Contract Minimums

Verify occurrence and aggregate limits against the subcontract requirements. Note: if the subcontractor has multiple projects under the same GL policy, the aggregate limit depletes across all projects. Some contracts require a project-specific aggregate endorsement (ISO CG 25 03 or CG 25 04) to protect the GC's project from aggregate erosion on other projects. Confirm whether the subcontract requires this endorsement.

Item 4: Additional Insured Endorsements CG 20 10 + CG 20 37

Both endorsements are typically required. CG 20 10 covers ongoing operations claims; CG 20 37 covers completed operations claims. The additional-insured status must appear either in the Description of Operations section of the ACORD 25 or as an attached endorsement page. A typed note saying "additional insured" without endorsement confirmation is insufficient.

Verify the endorsement edition dates if the contract specifies them. Many contracts require "CG 20 10 07 04 or equivalent" (the 2004 edition). The 2013 edition added "caused in whole or in part by" language that narrows coverage compared to earlier editions.

Item 5: Primary and Non-Contributory Language

The certificate or attached endorsement must confirm that coverage is primary and non-contributory as to the GC's additional insured status. Primary and non-contributory means the subcontractor's policy responds first to claims against the GC arising from the sub's work, without seeking contribution from the GC's own coverage. Without this language, the two insurers can dispute contribution allocation, delaying defense and indemnity.

The language typically appears in the Description of Operations: "Coverage is primary and non-contributory as respects [GC name]." This requires a specific endorsement (CG 20 01 or carrier equivalent) - it cannot simply be typed on the certificate.

Item 6: Waiver of Subrogation on GL and WC

The certificate must confirm waiver of subrogation on both the general liability policy and the workers' compensation/employers liability policy. Without a waiver of subrogation on the WC policy, if a subcontractor's employee is injured and the WC carrier pays, the WC carrier can subrogate against the GC for the portion of fault attributable to the GC. This is a significant exposure on construction projects.

The waiver of subrogation endorsement on WC is WC 00 03 13. On GL, the endorsement is CG 24 04 or carrier equivalent. Both must appear on the certificate or attached endorsements.

Item 7: Auto Covers All Owned/Non-Owned/Hired Vehicles

The auto liability section of the certificate must show "Any Auto" in the covered autos description, or must explicitly list all four categories: owned, non-owned, hired, and scheduled autos. A policy covering only "owned autos" leaves the GC exposed when subcontractor employees use personal vehicles for project-related work (non-owned auto) or rent vehicles (hired auto).

For commercial auto additional insured coverage, the CA 20 48 endorsement is required. The standard ACORD 25 auto section shows the named insured's auto coverage but does not grant additional insured status without CA 20 48 explicitly listed. See the detailed commercial auto section below.

Item 8: Workers' Compensation Covers All Employees

Workers' compensation must be in place for all employees of the subcontractor, including any workers classified as subcontractors or independent contractors. If the GC allows a sub onto the site without verified WC coverage and a worker is injured, the GC's own WC policy may be required to cover the claim. Some states impose this obligation by statute.

If the subcontractor is a sole proprietor exempt from WC requirements in their state, the GC should obtain written documentation of the exemption rather than relying on a blank WC section on the certificate.

Item 9: Umbrella Follows Form

The commercial umbrella or excess policy must follow form - meaning it provides the same terms and conditions as the underlying GL, auto, and WC policies, including additional insured status and waiver of subrogation. An umbrella that does not follow form may not extend the additional insured coverage above the primary limits, creating a gap between the primary limit and the umbrella limit.

The certificate should note "Umbrella/Excess follows form" or the attached umbrella endorsement should confirm it. Confirm umbrella limits meet the contract minimum - typically $2,000,000 for standard commercial construction, $5,000,000 for larger projects.

Item 10: No Exclusions for the Contracted Work Type

Review the Description of Operations and any attached endorsements for exclusions that would eliminate coverage for the specific type of work being performed. Common problematic exclusions in construction include:

• Residential construction exclusions (on a policy being used for mixed-use projects)
• Subsidence or earth movement exclusions (on excavation or foundation work)
• Professional liability exclusions that might apply to design-build components
• Total pollution exclusions that might apply to environmental contractors

A certificate that passes the first 9 items but contains an endorsement excluding the specific work type the sub is performing leaves the GC with no effective coverage for that work.

How to Handle Compliance Deficiencies

When a certificate fails any item on the checklist, the response is uniform: do not authorize work, and communicate the deficiency clearly to the subcontractor with a specific description of what needs to be corrected.

Most deficiencies fall into three categories.

Missing endorsements. The policy exists but the required endorsements (CG 20 10, CG 20 37, WC 00 03 13, CA 20 48) are not in place. The fix is a mid-term endorsement request from the insured to their carrier. Most carriers process these in 1 to 3 business days. The updated certificate should be reissued with the endorsements attached.

Insufficient limits. The policy limits are below the contract minimums. This requires a policy change or an umbrella endorsement to bring the limits to compliance. Depending on the insured's policy, this may require the carrier's underwriting approval and may increase premium.

Wrong named insured. The entity on the certificate does not match the contract. The agency needs to confirm whether the correct entity is covered and issue a corrected certificate, or help the insured obtain coverage for the correct entity if there is a genuine coverage gap.

Do not allow partial compliance. A GC who allows work to start with a non-compliant subcontractor COI - even with the intention of getting it fixed - has accepted the gap. If a claim occurs during that period, the GC bears exposure that the subcontractor's policy was supposed to cover.

Commercial Auto COI Requirements for Contractors

Commercial auto is the most frequently deficient line on contractor certificates. The standard ACORD 25 auto section shows that the named insured has auto coverage. It does not, by default, extend additional insured status for auto liability to the GC.

The CA 20 48 endorsement (Additional Insured - Designated Person or Organization for commercial auto) is the standard mechanism for extending AI status on auto policies. Without it, the GC has no direct claim under the subcontractor's auto policy if the GC is named in a suit involving the sub's vehicle.

For contractor accounts with significant fleet operations or multiple active projects with different GC requirements, blanket-additional-insured auto endorsements (CA 20 48 with blanket language) simplify management - the same endorsement covers all parties with a written contract requiring auto AI status.

The Description of Operations section of the ACORD 25 should note: "CA 20 48 attached - [GC name] is additional insured on auto liability for operations performed under contract." Without that notation and the actual endorsement attached, the auto AI requirement fails the compliance checklist.

For related workflows on managing contractor insurance requirements, see our guides on construction GL endorsements and subcontractor compliance management.

Frequently Asked Questions

What should a contractor COI include for a general contractor to accept it?

A compliant contractor COI must show: GL limits meeting contract minimums ($1M/$2M standard), auto liability ($1M CSL, all autos), WC (statutory limits with EL at $500K/$500K/$500K), umbrella following form ($2M+ minimum), additional insured endorsements CG 20 10 and CG 20 37 confirmed, primary and non-contributory language, waiver of subrogation on GL and WC, and no work-type exclusions. The named insured must match the subcontract entity exactly, and all policy periods must cover the work period.

Can work begin before the COI is received?

No. Allowing a subcontractor to begin work before receiving and verifying a compliant COI exposes the GC to uninsured claims arising during that period. Most prime contracts and owner-contractor agreements make the GC responsible for ensuring subcontractor insurance compliance. A GC who permits work without a compliant COI may face claims that the GC's own insurance must cover if the subcontractor's policy is later found deficient or non-existent.

What is CA 20 48 and why does it matter for contractor COIs?

CA 20 48 is the ISO endorsement that adds an additional insured to a commercial auto policy. Without CA 20 48, a certificate showing auto liability coverage does not extend AI status to the GC for auto liability claims. This is frequently missed on contractor certificates - the auto section shows coverage, but the GC has no direct claim right under the policy. CA 20 48 (or a blanket auto AI endorsement) must be confirmed on the certificate or attached endorsement.

How does a waiver of subrogation protect a general contractor?

A waiver of subrogation on the subcontractor's GL and WC policies prevents the sub's insurers from pursuing the GC after paying a claim. Without a waiver on the WC policy, if the sub's WC carrier pays an injured worker, the WC carrier can subrogate against the GC for the portion of fault assigned to the GC - potentially a significant dollar amount on a serious injury claim. The waiver of subrogation endorsements (WC 00 03 13 on WC, CG 24 04 on GL) eliminate this exposure.

What does "primary and non-contributory" mean on a contractor COI?

Primary and non-contributory language means the subcontractor's policy responds first to claims against the GC arising from the sub's operations, without seeking contribution from the GC's own coverage. Without this endorsement, when a claim is filed against both the sub and the GC, the sub's insurer and the GC's insurer may dispute how to split the defense and indemnity costs - delaying resolution and creating friction between the two coverage programs. CG 20 01 (or carrier equivalent) is the typical endorsement that establishes primary and non-contributory status.

What happens if a subcontractor's insurance lapses mid-project?

If a subcontractor's coverage lapses mid-project and the agency or GC catches it, work authorization should be suspended immediately until updated coverage and a new compliant COI are provided. If a claim occurs during a lapse period, the GC's own insurance may be required to respond, and the GC may then pursue the sub for breach of the subcontract insurance requirement. Agencies tracking subcontractor COI expirations with automated alerts prevent this scenario by catching lapse risks 30 to 90 days before expiration.

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

COI compliance verification should not be manual. BrokerageAudit's COI Manager tracks every certificate against contract requirements, flags deficiencies before work starts, and alerts you before policies expire. See COI Manager