Related:Certificate of InsuranceAdditional InsuredEndorsement
COIs, Subcontractor Insurance, and Workers' Comp Audits
Plain-language definitions and step-by-step guidance for the core concepts every general contractor, project manager, and subcontractor coordinator needs to know.
The most common questions general contractors and project managers ask about construction insurance, answered plainly.
A repeatable process for general contractors and project managers to collect, review, and track certificates of insurance before work begins.
Time
15–30 minutes per subcontractor
Tools needed
Review your subcontract and any upstream GC or owner requirements. Identify the required coverage types (GL, auto, umbrella, workers' comp), minimum limits, and endorsements (AI, PNC, waiver of subrogation). Write these down so you have a clear acceptance checklist before reviewing the certificate.
Contact the subcontractor (or their broker) and request a COI that names your company as an additional insured. Specify the form numbers you need (CG 20 10 and CG 20 37 for ongoing and completed operations), request PNC language if required, and ask for a waiver of subrogation endorsement. Include your company's legal name exactly as it should appear on the endorsement.
When the COI arrives, check every field systematically. Do not assume a COI is acceptable just because it was provided by the sub's broker.
Do not rely on the COI alone. Request copies of the actual endorsement pages from the sub's policy. Confirm CG 20 10 is attached for ongoing operations and CG 20 37 for completed operations. Verify PNC language and waiver of subrogation endorsements if required. The endorsement must name your company.
Confirm the sub carries workers' comp for all employees and, if required, verify their EMR meets your threshold. If the sub uses sub-subcontractors, require those subs to provide their own COIs to you. Check your state's statutory employer rules: in many states, if a sub's worker is injured and the sub is uninsured, the upstream contractor (you) may be liable.
File the original COI and endorsement copies in a searchable system organized by subcontractor and project. Set calendar reminders 30 and 60 days before each policy expiration. Do not allow subs to work on-site with expired coverage. A single day without a valid COI during an incident can create uncovered exposure.
Want a pre-built checklist you can hand to your team?
Download the COI & Endorsement ChecklistPrecise definitions of the terms you will encounter in construction contracts, COIs, and insurance audits.
Why endorsement edition dates matter
The same form number can provide very different coverage depending on its edition date. For example, CG 20 10 11 85 is widely considered unacceptable because it can extend coverage to the additional insured's sole negligence, while the 04 13 and 12 19 editions are preferred for their appropriate limitations. Always confirm the full form number including the edition date (e.g., CG 20 10 04 13, not just CG 20 10).
Related:Certificate of InsuranceAdditional InsuredEndorsement
Related:General LiabilityInstallation Floater
Related:CG 20 37General Liability
Related:Workers' CompensationPremium AuditNCCI
Related:CG 20 10CG 20 37Primary and NoncontributoryWaiver of Subrogation
Related:Additional InsuredCompleted OperationsUmbrella / Excess Liability
Related:General LiabilityAuto LiabilityWorkers' Compensation
Related:EndorsementPrimary and NoncontributoryAdditional Insured
These are the most frequently missed issues when reviewing subcontractor certificates of insurance.
When you receive a COI, review these specific items before approving the sub to mobilize. Each of these issues has caused real claims exposure for contractors who did not catch them in advance.
The policy listed on the COI expired before the current date or will expire before the project is complete. A lapsed policy means no coverage for any incident during the gap, even one day. Always check each line individually; GL and workers’ comp often renew on different dates.
The COI or endorsements only show CG 20 10 (ongoing operations) but not CG 20 37. This is one of the most common and expensive gaps in construction insurance. Once work is finished, your AI status evaporates under CG 20 10 alone. Completed operations claims such as defective work and latent defects are common years after project completion.
The entity on the COI is a DBA, trade name, parent company, or related entity that is not the party you contracted with. Coverage applies to the named insured; if the entity is different, the policy may not respond to a claim arising from work performed under your contract.
The sub’s policy limits are lower than what your contract requires. For example, the contract requires $2M aggregate GL but the COI shows $1M. Inadequate limits leave you exposed for the difference in any claim exceeding the sub’s coverage.
The COI may note "additional insured" in the Description of Operations box but does not include a PNC endorsement. Without PNC, in a covered loss both the sub’s insurer and your insurer share the claim, extending resolution time and potentially eroding your own policy limits.
The COI states "additional insured per contract" or lists you in the Description of Operations, but the actual endorsement form (CG 20 10 / CG 20 37) has not been provided. These COI notations are not binding on the insurer. The endorsement must be physically attached to the policy.
The sub’s COI shows no workers’ compensation coverage or lists "N/A (sole proprietor)." In many states, a sole proprietor may be exempt, but if they have any employees or use labor-only sub-subcontractors, coverage may be required. Confirm the statutory rules in your project state before accepting this exclusion.
Waivers are sometimes included on GL but omitted from the workers’ comp line. If a sub’s injured worker receives WC benefits and the insurer retains subrogation rights, they can sue you as the GC for contribution to the loss.
Workers' compensation rules vary significantly by state. The examples below illustrate how statutory employer liability and premium audit obligations can affect GCs.
The following is a general summary for educational purposes only and is not legal advice. Statutes and regulations change; consult a licensed attorney or insurance professional in the relevant state before relying on this information.
Florida Statute 440.10 imposes statutory employer liability on any contractor who subcontracts work to a subcontractor that does not carry workers’ compensation. If a sub’s employee is injured and the sub is uninsured, the GC is liable for those WC benefits. This applies to general contractors and subcontractors in the contracting chain.
Florida Statute 440.10
North Carolina General Statute 97-19 similarly imposes liability on a principal contractor for workers’ compensation benefits owed to employees of a subcontractor who fails to carry coverage. The statute creates a broad duty to ensure subcontractors are insured before work begins.
NC General Statute 97-19
Texas is unique among U.S. states in that workers’ compensation is generally non-subscriber (not mandatory for most private employers). However, contractors working on government projects must carry WC, and the Texas Department of Insurance has noted that ACORD certificates are informational only and cannot alter policy coverage. Endorsements control.
Texas Department of Insurance guidance on COIs
California Labor Code Section 3602 et seq. governs workers’ compensation. California has aggressive enforcement of WC requirements, and GCs are routinely held liable for uninsured subs’ workers’ injuries. The state also requires any subcontractor with employees to maintain WC; sole proprietors may opt out but can opt back in.
California Labor Code Section 3700
Starting-point language for the three most commonly required endorsements in construction subcontracts. Have your attorney review and adapt this language before using it in contracts.
The following sample language is provided for educational and illustrative purposes only. It is not legal advice, does not constitute a legal opinion, and should not be used as-is without review by a licensed attorney familiar with the laws of the applicable jurisdiction.
Request both ongoing and completed operations AI endorsements on the sub’s GL policy. Missing CG 20 37 is the most common and costly COI gap in construction.
Sample request language
Subcontractor shall maintain Commercial General Liability insurance with limits no less than $[LIMIT] per occurrence and $[LIMIT] aggregate, naming [GC Legal Name] as an Additional Insured for both ongoing operations (ISO form CG 20 10 or equivalent) and completed operations (ISO form CG 20 37 or equivalent). Coverage for completed operations shall be maintained for a period of not less than [X] years following final completion of the Work.
Require the sub’s GL to respond first on any covered claim involving both the sub’s policy and the GC’s policy. This prevents dual-trigger disputes that delay claims resolution.
Sample request language
Subcontractor's Commercial General Liability insurance shall be endorsed to be primary and noncontributory with respect to any other insurance or self-insurance maintained by [GC Legal Name]. In no event shall [GC Legal Name]'s insurance be called upon to contribute to a loss covered by Subcontractor's insurance.
Require the sub’s insurers to waive subrogation rights against the GC and owner across all required lines, including workers’ compensation.
Sample request language
Subcontractor waives, and shall cause its insurers to waive, all rights of recovery or subrogation against [GC Legal Name], [Owner Legal Name], and their respective officers, directors, employees, and agents with respect to losses payable under Subcontractor's Commercial General Liability, Automobile Liability, Workers' Compensation, and Employer's Liability policies.
This glossary is provided for general educational purposes and does not constitute legal, insurance, or financial advice. Coverage terms, endorsement forms, and statutory obligations vary by carrier, policy, and jurisdiction. Always confirm the specific language of your policies and contracts with a licensed insurance professional or attorney.
RiskWise automates subcontractor compliance tracking — expiration alerts, a COI status dashboard, and year-end audit prep — so you are never caught with a lapsed policy.