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Commercial General Liability (CGL)

Coverage Trigger

The event or condition that activates coverage under an insurance policy, such as an occurrence, a claim being made, or manifestation of injury.

What It Is

A coverage trigger is the event or condition that determines which policy responds to a claim. In CGL insurance, the two primary coverage triggers are occurrence and claims-made. Under an occurrence trigger, the policy in effect when the bodily injury or property damage takes place responds to the claim. Under a claims-made trigger, the policy in effect when the claim is first made or reported responds.

For long-tail exposures — where injury or damage develops over extended periods — the coverage trigger question becomes complex. Courts have adopted different theories, including the exposure theory (the policy in effect during exposure triggers), the manifestation theory (the policy in effect when the injury manifests triggers), the injury-in-fact theory (the policy in effect when the actual injury occurs triggers), and the continuous trigger theory (all policies from exposure through manifestation trigger).

The coverage trigger directly affects which policy year's limits are available and which insurer bears the defense and indemnity obligation.

Why It Matters for Brokers

Brokers must understand coverage triggers to properly advise clients on policy structure, especially when transitioning between carriers or between occurrence and claims-made forms. A gap in the coverage trigger chain — such as switching from occurrence to claims-made without proper retroactive date management — can leave the client without coverage for a period of time. This is particularly critical for long-tail exposures like construction defects, environmental contamination, and product liability.

Real-World Example

A building contractor installs defective insulation in 2022 (occurrence policy with Carrier A), switches to Carrier B in 2023 (occurrence), and to Carrier C in 2024 (claims-made with retroactive date of 1/1/2024). In 2025, mold resulting from the 2022 installation is discovered and a $600,000 claim is filed. Under the occurrence trigger, Carrier A's 2022 policy responds. But if the mold damage was continuous from 2022-2025, multiple policies may be triggered. Carrier C's claims-made policy would not cover it because the retroactive date of 1/1/2024 excludes acts prior to that date.

Common Mistakes

  • 1Switching a client from occurrence to claims-made without purchasing an extended reporting period from the expiring carrier or negotiating a full prior acts retroactive date.
  • 2Not understanding which trigger theory applies in the client's jurisdiction, leading to incorrect advice about which policy year responds.
  • 3Failing to document the coverage trigger on certificates and policy summaries, creating confusion during claims.

How brokerageaudit.com Handles This

Policy Checker identifies the coverage trigger on every liability policy and prominently displays it in the policy summary. It flags any change in coverage trigger between expiring and renewal policies as a critical coverage change. It also tracks retroactive dates on claims-made policies and alerts brokers when a new policy's retroactive date creates a potential gap.

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