The Broker's Guide to Who Needs A Certificate Of Insurance

A certificate of insurance (COI) is required any time one party needs documented proof that another party carries specific insurance coverage before a business relationship begins, a lease is signed, a project starts, or a contract is awarded. The requesting party is the certificate holder. They are not asking to see the policy - they are asking for a standardized summary on ACORD 25 that confirms the coverage exists, the limits meet their contractual requirements, and the policy has not lapsed.

For insurance producers managing commercial accounts, understanding who requests COIs and why is the first step to managing the volume efficiently. The agency, not the insured, is typically the one assembling and issuing these documents on behalf of the client.

Key Takeaways

• Landlords, general contractors, lenders, project owners, major retailers, and municipalities all require COIs before a business relationship begins.
• A missing or deficient COI stops real work: leases do not get signed, subcontractors do not start work, contracts do not get awarded.
• New COIs are needed at every policy renewal, when coverage changes, when a new project starts, and when a new certificate holder relationship begins.
• Individual consumers buying personal insurance generally do not need COIs - except renters who may be required by landlords to provide proof of renters insurance.
• Agencies managing 50+ active commercial accounts typically issue hundreds to thousands of COI requests annually, making manual processing unsustainable.

Who Requests COIs and Why

Landlords Requiring Tenant COIs

Commercial landlords require tenants to carry general liability insurance and name the landlord as additional insured as a standard lease condition. The COI is required before lease execution and at every annual renewal. Residential landlords increasingly require renters insurance COIs - common in managed apartment communities - typically with minimum GL limits of $100,000 to $300,000.

The landlord's exposure is straightforward: if a customer slips in the tenant's retail space and sues both the tenant and the property owner, the landlord wants coverage through the tenant's GL policy rather than having to defend independently.

General Contractors Requiring Subcontractor COIs

This is the highest-volume COI request category in commercial insurance. General contractors require COIs from every subcontractor before allowing them on a jobsite. The typical GC requirement package includes GL ($1M/$2M), auto liability ($1M CSL), workers' compensation (statutory), umbrella ($2M+), and additional insured endorsements CG 20 10 (ongoing operations) and CG 20 37 (completed operations).

A GC with 40 active subcontractors on a mid-size commercial project may manage 40 separate COIs, each needing verification against the subcontract requirements before work authorization. Missing or non-compliant subcontractor COIs are a leading cause of project delays.

Lenders Requiring Borrower COIs

Commercial lenders require COIs at loan closing as a condition of funding. The lender needs to confirm that the property securing the loan is insured and that the lender is named as an additional insured or loss payee on the property policy. SBA lenders, commercial real estate lenders, and equipment financiers all follow this pattern.

The COI requirement does not end at closing. Lenders typically require annual COI renewals for the duration of the loan term. A lapsed policy or a COI not delivered on time can trigger a technical default under many commercial loan agreements.

Project Owners Requiring Contractor COIs

Large project owners - construction developers, REITs, public agencies, hospitals - require COIs from their prime contractors as a condition of the contract. Public works contracts typically require COIs before the notice to proceed is issued. Private developers often require them before the first draw request is processed.

Project owner requirements tend to be more detailed than GC requirements. They frequently specify ISO endorsement form numbers (CG 20 10 10 01 or later edition), primary and non-contributory language, and waiver of subrogation. These specifications need to appear on the certificate or as attached endorsements.

Retailers Requiring Vendor COIs

Major retailers require COIs from vendors providing services on their premises. Walmart requires vendors and contractors working in or delivering to its stores to carry minimum GL limits of $1,000,000 per occurrence / $2,000,000 aggregate, with Walmart named as additional insured. Home Depot has similar requirements through its supplier and contractor programs.

Vendor agreements with large retailers often include certificates of insurance as an exhibit to the contract. The retailer's risk management department reviews and must accept the COI before the vendor relationship activates.

Municipalities Requiring Contractor COIs

City, county, and state government contracts universally require COIs. Public contracts add requirements that private contracts do not always include: the municipality is often required to be named as additional insured under state procurement statutes, primary and non-contributory language is standard, and some public contracts require umbrella limits of $5,000,000 or higher for large infrastructure projects.

Government contracts often use their own insurance requirement forms rather than simply accepting an ACORD 25. The insurance producer needs to match the certificate to each municipality's specific form requirements.

What Happens When You Cannot Produce a COI

The consequences of a missing or non-compliant COI are immediate and practical.

A subcontractor without a compliant COI does not start work. The GC will not issue work authorization - doing so creates potential coverage gaps and puts the GC's own insurance program at risk. If work has already started and the COI lapses or is found deficient, the GC can issue a stop-work notice until compliance is restored.

A commercial tenant without a required COI does not sign the lease. Landlords with institutional capital behind them - REITs, private equity-backed property companies - have standardized processes that block lease execution until the insurance requirements are verified. The lease is simply not countersigned.

A vendor without a compliant COI does not get a Walmart or Home Depot vendor number activated. The retailer's supplier onboarding system flags the insurance requirement as incomplete and the relationship does not proceed.

For the agency, this means a client calling with an urgent COI request at 4 PM on a Friday is not an inconvenience - it is a business-critical situation for the client. Delays in producing compliant COIs directly affect the client's ability to operate.

Who Does NOT Need a COI

Individual consumers buying personal insurance - homeowners, auto, life, health - generally do not need COIs. These are personal lines policies, and the policyholder is not typically in a contractual relationship that requires proof of coverage to a third party.

The exception is renters insurance. Some landlords, particularly professionally managed apartment communities, require tenants to carry renters insurance and provide proof of coverage. In that case, the tenant does need a COI (or a declarations page accepted in lieu of an ACORD certificate). The required limit is typically $100,000 personal liability.

Personal umbrella policies do not generate COI requests. Commercial umbrella policies, which sit above GL, auto, and workers' compensation policies, do appear on contractor COIs - the umbrella limits are relevant to GC and project owner requirements.

How Often Are New COIs Needed

A COI is a snapshot of coverage as of the issue date. It becomes outdated in four situations:

Policy renewal. Every time a policy renews, the old COI shows expired policy dates. Certificate holders often require updated COIs at renewal. Agencies managing 300 active commercial accounts may process 1,000+ renewal COIs per year.

Coverage change. Any mid-term policy change that affects limits, endorsements, or carriers requires a new COI for all active certificate holders.

New project or contract. Each new project owner, GC, or landlord relationship requires a new COI with that party named as certificate holder (and often additional insured).

New certificate holder relationship. When a client adds a new vendor, lender, or business relationship that requires insurance documentation, a new COI is generated for that specific relationship.

The compounding effect is significant. A mid-size contractor with 12 active projects, 3 annual policy renewals across GL, auto, WC, and umbrella lines, and 40 active subcontractor relationships on the upstream side can generate 400+ COI transactions per year.

The Agency's Role in Managing COI Requests at Scale

The agency is the operational hub for COI management. Clients do not issue their own ACORD 25 certificates - the licensed insurance producer does. This means every COI request from every subcontractor, landlord, lender, and project owner comes to the agency.

For agencies with a handful of commercial accounts, manual COI management works. A producer pulls up the account, confirms coverage, fills in the ACORD 25, and emails it. For agencies managing 50+ commercial accounts with active COI obligations, this becomes a full-time workload separate from the rest of account servicing.

Blanket additional insured endorsements reduce some of the complexity on the additional insured verification side - rather than checking each new certificate holder against individual scheduled endorsements, the blanket endorsement covers all parties with a written contract requiring additional insured status. But the COI still has to be issued, tracked, and renewed.

BrokerageAudit's COI Manager centralizes COI issuance and tracking, connecting each certificate to the underlying policy data and alerting the agency when renewals are due. See how we help agencies handle COI volume at /compare.

For more on how COIs connect to additional insured requirements, see our guide at post #126, and for renewal workflow specifics, see post #130.

Frequently Asked Questions

Who requires a certificate of insurance before work can start?

General contractors require COIs from every subcontractor before allowing work on a jobsite. The requirement typically includes GL ($1M/$2M), auto liability ($1M CSL), workers' compensation, umbrella coverage, and CG 20 10/CG 20 37 additional insured endorsements. Work authorization is withheld until the COI is received and verified against the subcontract insurance requirements.

Do landlords require tenants to provide a certificate of insurance?

Commercial landlords universally require COIs from tenants as a condition of lease signing. Residential landlords, particularly professionally managed properties, increasingly require renters insurance COIs. The COI must show the landlord as certificate holder and, in most commercial leases, as additional insured. The landlord's specific requirements are spelled out in the lease's insurance clause.

What happens if a subcontractor cannot produce a COI?

The subcontractor does not start work. The general contractor will not issue work authorization without a compliant COI, because allowing an uninsured subcontractor onto the jobsite creates direct exposure for the GC. If work has already started and the COI lapses, the GC can issue a stop-work notice. Some prime contracts require the GC to remove non-compliant subcontractors from the project entirely.

Does an individual with personal insurance need a COI?

Generally no. Personal lines policyholders - homeowners, auto, life insurance customers - do not need COIs. The exception is renters: some landlords require renters insurance proof as a lease condition. Small business owners operating under personal lines coverage may find their coverage insufficient and need to transition to commercial GL, which does generate COI requirements as the business takes on contracts.

How often does a certificate of insurance need to be updated?

A COI needs to be updated at every policy renewal, when any covered policy changes mid-term, when a new project begins requiring a new certificate holder, and when a certificate holder's specific requirements change. Annual renewal is the baseline frequency, but high-volume contractors may generate hundreds of updated certificates mid-year as projects start and coverage changes.

Who issues a certificate of insurance - the insured or the agent?

The licensed insurance producer issues the COI, not the insured. An insured cannot legally issue their own ACORD 25 certificate. The agency issues the certificate on behalf of the insured, and the certificate must accurately reflect the actual policy coverage at the time of issuance. Issuing a certificate that overstates coverage - for example, claiming additional insured status that is not on the policy - creates E&O exposure for the agency.

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

COI volume is manageable with the right system. BrokerageAudit's COI Manager handles issuance, certificate holder tracking, and renewal alerts - so your team handles client relationships instead of chasing paperwork. See COI Manager