How to Master Acord 25 Vs Acord 28 Differences in Your Agency

Understanding ACORD 25 vs ACORD 28 differences is one of the most practical skills a commercial lines broker can develop. Both forms are ACORD certificates, both document insurance coverage, and both carry authorized representative signatures. But they cover completely different coverage types, go to different parties, and serve different legal functions. Issuing the wrong form to the wrong party is a common error that creates delays, rejected certificates, and in some cases, material gaps in documented coverage.

This guide covers both forms in detail, explains when to use each, and addresses the scenarios where you need to issue both on the same account.

Key Takeaways

• ACORD 25 documents liability coverage (GL, auto, umbrella, workers' comp) and goes to certificate holders such as landlords, general contractors, and project owners. ACORD 28 documents commercial property coverage and goes to loss payees and additional interests such as lenders and equipment lessors.
• Issuing an ACORD 25 to a lender requiring proof of commercial property insurance is the most common ACORD form selection error - the lender needs an ACORD 28, not an ACORD 25 (ACORD 2025 form guidance).
• ACORD 28 can establish loss payee status for the financial institution or mortgagee listed on the form; ACORD 25 confers no legal rights or coverage interests on the certificate holder.
• Commercial leases frequently require both forms: ACORD 25 for GL and workers' comp, and ACORD 28 for the tenant's property and business income coverage.
• ACORD 27 covers personal lines property; ACORD 28 covers commercial lines property. Using ACORD 27 for a commercial account creates a documentation mismatch.
• Both ACORD 25 and ACORD 28 carry 30-day standard cancellation notice and require an authorized representative signature to be considered executed.

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What Is the ACORD 25?

The ACORD 25 is the Certificate of Liability Insurance. It documents liability-side coverages only:

• Commercial General Liability (occurrence or claims-made)
• Automobile Liability (any auto, owned, hired, non-owned)
• Umbrella and Excess Liability
• Workers' Compensation and Employers Liability
• Other liability lines (professional liability, cyber, etc.) in the "Other" rows

The ACORD 25 goes to certificate holders: parties who need to verify that the named insured carries liability insurance. Common recipients include general contractors requiring proof of a subcontractor's CGL, commercial landlords requiring proof of a tenant's GL and WC, government agencies requiring proof of vendor liability coverage, and project owners requiring proof of contractor coverage.

The ACORD 25 form itself is explicit: it "confers no rights upon the certificate holder" and "does not amend, extend or alter the coverage afforded by the policies" listed on it. The certificate holder gets information, not coverage. Additional insured status (if required) must come from an endorsement, not from the certificate itself.

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What Is the ACORD 28?

The ACORD 28 is the Evidence of Commercial Property Insurance. It documents property-side coverages:

• Commercial Property (building and/or business personal property)
• Business Income and Extra Expense
• Inland Marine
• Equipment Breakdown
• Other property-related coverage lines

The ACORD 28 goes to loss payees, mortgagees, and additional interests: parties with a financial stake in the physical property being insured. Common recipients include banks and lenders financing commercial real estate (who need proof that their collateral is insured), equipment lessors requiring proof that leased equipment is covered under the lessee's property policy, commercial landlords requiring proof that a tenant carries property and business income insurance, and government agencies requiring evidence of property coverage as a contract condition.

Unlike the ACORD 25, the ACORD 28 can establish a legal interest. When a lender is listed as a Loss Payee or Mortgagee on the ACORD 28, and the underlying policy also carries that designation, the lender has a contractual right to receive insurance proceeds directly in the event of a covered property loss. This is a meaningful legal distinction from the ACORD 25's position as a purely informational document.

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ACORD 25 vs ACORD 28: Head-to-Head Comparison

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When to Issue an ACORD 25

Issue an ACORD 25 whenever a party requires proof that the named insured carries liability insurance. The most common scenarios:

Construction contracts: General contractors require certificates from every subcontractor before they step on a job site. The certificate documents GL, auto, WC, and umbrella coverage. The GC typically needs to be listed as an Additional Insured on the GL and umbrella, which requires endorsements, not just a checked box.

Commercial leases: Landlords require tenants to maintain GL coverage as a lease condition. The ACORD 25 documents that coverage. If the landlord also requires proof of the tenant's property and business income insurance, the ACORD 25 alone is insufficient - an ACORD 28 is also needed.

Service agreements: Clients hiring consultants, contractors, or service providers often require COIs before work begins. The ACORD 25 covers the liability side of the vendor's insurance program.

Government contracts: Federal, state, and municipal contracts frequently specify minimum liability limits and require the government entity to be named as an Additional Insured. ACORD 25 documents compliance.

Commercial loans (liability side): A lender financing a construction or renovation project may want proof that the borrower/contractor carries GL during the project. ACORD 25 covers this. But if the lender also needs proof of commercial property insurance on the building, they need an ACORD 28.

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When to Issue an ACORD 28

Issue an ACORD 28 whenever a party requires proof of commercial property insurance coverage. The most common scenarios:

Commercial mortgage lenders: When a bank finances commercial real estate, the loan agreement requires property insurance on the collateral. The lender needs to be listed as a Mortgagee or Loss Payee on the policy. The ACORD 28 documents this and identifies the lender's interest.

Equipment lessors: A company leasing heavy equipment to a business may require proof that the business's property policy covers the leased equipment. The ACORD 28 documents the evidence and can list the lessor as a Loss Payee or Additional Interest.

Commercial landlords (property side): A landlord may require a commercial tenant to carry property insurance on tenant improvements and business personal property, plus business income coverage. The ACORD 28 evidences this coverage. Note: the landlord may also want an ACORD 25 for GL and WC - the ACORD 28 only addresses the property side.

SBA loans: The Small Business Administration requires borrowers to carry property insurance on business assets pledged as collateral. Lenders use the ACORD 28 as evidence. (ACORD 2025 form guidance confirms ACORD 28 as the appropriate form for this purpose.)

Government property requirements: Some government contracts require contractors to maintain insurance on government-furnished property or on structures the contractor occupies. ACORD 28 evidences that coverage.

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When You Need Both ACORD 25 and ACORD 28

Many commercial accounts require both forms. Understanding when to issue both prevents the most common certificate gap:

Commercial leases with dual requirements: The lease requires the tenant to carry (a) General Liability insurance and Workers' Compensation, and (b) property insurance on tenant improvements and business personal property plus business income coverage. ACORD 25 documents (a). ACORD 28 documents (b). Issuing only the ACORD 25 leaves the landlord without evidence of property coverage, which puts the tenant in breach of the lease insurance requirement.

Commercial real estate loans with operating businesses: A bank finances a commercial building where the borrower operates a business. The bank needs the ACORD 28 for the property policy (building and/or business personal property). If the loan agreement also requires the borrower to carry GL, the bank may want an ACORD 25 as well. Two separate forms, two separate coverage types.

Construction projects with financed property: A developer building a commercial project has a construction loan (lender needs ACORD 28 for builder's risk or property coverage) and also has subcontractors requiring COIs (ACORD 25 for each subcontractor's liability coverage). The developer's own ACORD 25 goes to the general contractor or owner. The ACORD 28 goes to the lender.

Equipment-intensive businesses: A manufacturer leases production equipment (ACORD 28 goes to the equipment lessor) and also works under contracts requiring proof of liability (ACORD 25 goes to the client). Two forms, two recipients, two separate coverage categories.

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The Most Common Confusion: Issuing ACORD 25 to a Lender

The most frequent ACORD form selection error is sending an ACORD 25 to a lender who asked for proof of commercial property insurance. The lender needs an ACORD 28. The ACORD 25 documents liability coverages only. It has no field for commercial property limits, no Loss Payee designation, and no coverage relevant to the lender's collateral protection requirement.

This error usually arises in two scenarios:

Scenario A: The agent does not distinguish between the two forms and issues whichever certificate they use most frequently - typically the ACORD 25 - regardless of what was requested.

Scenario B: The lender's request says "certificate of insurance" without specifying which ACORD form, and the agent defaults to the ACORD 25 without reading the underlying coverage requirement.

When a lender receives an ACORD 25 instead of an ACORD 28, the lender's compliance team typically rejects it and requests the correct form. This creates re-work and delays. In a loan closing scenario, those delays can have real cost implications for the borrower-client. The fix is simple: read the request carefully and identify whether the requester needs proof of liability coverage (ACORD 25) or proof of property coverage (ACORD 28).

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ACORD 27 vs ACORD 28: A Quick Distinction

ACORD maintains two evidence-of-property forms:

ACORD 27 is the Evidence of Personal Property Insurance. It covers personal lines property policies: homeowners, renters, scheduled personal property. It goes to personal lines clients' mortgage lenders and personal property lessors.

ACORD 28 is the Evidence of Commercial Property Insurance. It covers commercial lines property policies.

Using ACORD 27 for a commercial account creates a documentation mismatch. The form fields differ, and a commercial lender's compliance team will recognize that a personal lines evidence form is not appropriate for a commercial property policy. If a client has a commercial property policy and needs evidence for a lender, use ACORD 28.

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Which ACORD Form to Use: Quick Reference

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Practical Workflow: How to Select the Right Form Every Time

Step 1: Read the Certificate Request

Do not issue a form until you know exactly what coverage the requester needs documented. Read the contract language or written request. Key words:

• "Liability insurance," "general liability," "auto liability," "workers' comp" - ACORD 25
• "Property insurance," "building insurance," "business personal property," "business income," "loss payee," "mortgagee" - ACORD 28

Step 2: Identify the Recipient's Legal Interest

Is the requester a party who needs to verify liability coverage (certificate holder) or a party with a financial interest in the property (loss payee, mortgagee)? The answer determines the form.

Step 3: Check for Dual Requirements

Read the contract or loan agreement fully. Many documents require both liability and property evidence. Issue both forms if the contract requires both.

Step 4: Pull the Correct Policy

ACORD 25 pulls from the GL, auto, WC, and umbrella policies. ACORD 28 pulls from the commercial property policy. These are separate policies with separate declarations pages. Do not mix them.

Step 5: Match the Form to the Policy Type

Confirm that the coverage type on the form matches the policy type you are documenting. If you are completing an ACORD 28 and the client's property policy is not listed as an ACORD 28-compatible policy type, stop and re-verify what coverage the requester actually needs.

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Frequently Asked Questions

What is the difference between ACORD 25 and ACORD 28?

ACORD 25 is the Certificate of Liability Insurance, covering liability lines: general liability, auto, umbrella, and workers' compensation. It goes to certificate holders who need proof of liability coverage. ACORD 28 is the Evidence of Commercial Property Insurance, covering commercial property lines: building, business personal property, business income, and inland marine. It goes to loss payees and mortgagees who need proof of property coverage. The two forms cover entirely different coverage types and serve different parties.

When does a lender require an ACORD 28 instead of an ACORD 25?

A lender requires an ACORD 28 whenever they need evidence that a commercial property policy is in force and that their financial interest (as mortgagee or loss payee) is recognized. This applies to commercial real estate loans, SBA loans secured by business property, and equipment financing arrangements. The ACORD 25 documents only liability coverage and has no Loss Payee or Mortgagee fields. A lender who receives an ACORD 25 instead of an ACORD 28 cannot use it to document their property insurance requirement.

Can you use ACORD 25 to show commercial property coverage?

No. The ACORD 25 documents liability coverages only: CGL, auto, umbrella, and workers' compensation. It has no fields for commercial property limits, building values, business income limits, or loss payee designations. If a party needs evidence of commercial property insurance, the correct form is the ACORD 28. Using an ACORD 25 in response to a property insurance request will result in rejection and re-work.

What does an ACORD 28 loss payee designation actually mean?

An ACORD 28 loss payee designation identifies a party that has a financial interest in the insured property and is entitled to receive insurance proceeds directly if a covered property loss occurs. For example, a bank holding a commercial mortgage is listed as a Mortgagee/Loss Payee on the property policy. If the building suffers a fire loss, the carrier pays proceeds to both the insured and the lender (up to the lender's outstanding loan balance). The ACORD 28 evidences this arrangement. This is a meaningful legal interest, distinct from the certificate holder on an ACORD 25 who receives no coverage rights from the certificate.

When do you need to issue both ACORD 25 and ACORD 28 for the same account?

You need both forms whenever a requester requires evidence of both liability and property coverage. The most common scenarios: commercial leases that require tenants to carry GL, WC, and property/BI insurance; commercial real estate loans where the lender requires both liability and property evidence; and construction projects with a financed component. In each case, the ACORD 25 covers the liability side and the ACORD 28 covers the property side. One form cannot substitute for the other.

What is the difference between ACORD 27 and ACORD 28?

ACORD 27 (Evidence of Personal Property Insurance) covers personal lines property policies: homeowners, renters, and scheduled personal property. It is used for personal lines clients whose mortgage lender or personal property lessor needs evidence of insurance. ACORD 28 (Evidence of Commercial Property Insurance) covers commercial lines property policies and is used for commercial accounts. Using ACORD 27 for a commercial property policy creates a form mismatch that commercial lenders will reject. If the client has a commercial property policy, use ACORD 28.

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Related terms: Acord Form, Loss Payee, Certificate Of Insurance

Related posts: #151, #152

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