Most subcontractors know they need to provide certificates of insurance before starting work. Most GC admins know they need to collect them. The problem is in the gap between those two things — a sub sends their standard certificate, the admin files it, and neither party realizes the COI for subcontractors doesn't actually meet the GC's contract requirements. This guide covers what a compliant sub COI looks like, what subs get wrong, and how GC offices can collect what they actually need.
The most common mistake: A sub sends their standard certificate — the one their broker has on file — and the GC accepts it. That certificate names the agent as certificate holder, carries blanket limits, and includes no project-specific endorsements. It satisfies the "we got a COI" checkbox. It does not satisfy the GC's actual contract requirements.
Certificates of insurance for subcontractors — what makes them different
Certificates of insurance for subcontractors are not the same as the standard certificate a vendor provides in a retail or service context. A sub's COI for subcontractors working on a GC's job site must reflect project-specific endorsements: the GC named as additional insured, primary and noncontributory language, waiver of subrogation, and — for construction — completed operations coverage extending past project completion.
A standard certificate from the sub's broker covers the insurance. The project-specific COI for subcontractors covers the liability transfer that a GC's contract actually requires. The sections below explain the difference field by field.
What coverage a subcontractor needs to provide
Before you chase a sub for a certificate, be clear on what you're actually requiring. Four coverage types are standard on virtually every commercial subcontract. Two additional types apply to specific scopes.
General Liability
Required on every subcontract
Covers bodily injury, property damage, and personal injury arising from the sub's work. Minimum limits depend on project type: $1M per occurrence / $2M aggregate is the floor for most commercial work. Larger commercial projects, public work, or owner requirements frequently push to $2M/$4M or $5M/$10M. Your prime contract's insurance exhibit drives the minimum you pass to your subs.
Require occurrence form, not claims-made. If a sub carries claims-made, require tail coverage extending past your state's construction defect statute of limitations.
Workers' Compensation
Required in every state where the sub has employees
Covers medical expenses and lost wages for a sub's employees injured on the job. Required by law in 49 states for employers (Texas is the only state where it is elective). Even in states where sole proprietors can exempt themselves, require WC contractually — or require documentation of the exemption. A sub without WC who is injured on your site creates significant liability exposure for the GC.
Commercial Auto Liability
Required when vehicles are on site or used for project work
Covers bodily injury and property damage from vehicles owned, hired, or non-owned by the sub and used in connection with the project. $1M combined single limit is standard. If the sub uses their own vehicle to haul materials or tools to your job site, auto liability is required. If they take a taxi to the site, it is not.
Umbrella / Excess Liability
Required when primary limits cannot meet project minimums
Sits on top of GL, auto, and WC to bring total coverage to the project's required minimums. If a prime contract requires $5M in total liability coverage and the sub carries $1M GL, they need a $4M umbrella that follows form to the underlying GL. Confirm the umbrella explicitly follows form — including additional insured status and primary/noncontributory language.
Two additional types apply to specific scopes:
Professional Liability (E&O) — required for design-build subs, engineers, architects, or any sub providing design services alongside installation. GL does not cover design errors; only a professional liability policy does.
Pollution Liability — required for environmental trades: asbestos abatement, mold remediation, demolition work that may disturb hazardous materials. GL explicitly excludes most pollution events.
Why a standard certificate isn't enough
When a sub requests a certificate from their broker for the first time, the broker typically produces a standard certificate: the sub's name and address, the carrier, current policy numbers and limits, and the agent's own office as the certificate holder. This certificate lives in the broker's system and gets emailed to anyone who asks.
That certificate satisfies the question "does this sub have insurance?" It does not satisfy the question "does this sub's insurance meet my contract requirements for this project?"
Standard certificate
Agent's office as certificate holder
Blanket policy limits
No project address
No additional insured endorsements
No primary/noncontributory language
No waiver of subrogation
Project-specific certificate
GC (and owner if required) as certificate holder
Limits meet project minimums
Project address in Description of Operations
CG 2010 / CG 2037 endorsement numbers
Primary and noncontributory language
Waiver of subrogation endorsed
The difference is not that the sub needs a different insurance policy. The difference is that the certificate issued to the GC must reflect the project-specific endorsements already on the policy — or endorsements the sub needs to request from their broker before the certificate can be accurate.
Most subs understand the COI process. What they often do not understand is why you are sending the certificate back after you receive it. The sections below explain the three main reasons.
The additional insured requirement — what subs need to know
Additional insured status gives the GC the right to make a claim directly on the sub's policy if the sub's work causes a loss. Without it, the GC must use their own policy — and the sub's insurer has no obligation to defend the GC.
The most persistent confusion in subcontractor COI management: a name written in the Description of Operations box does not make anyone an additional insured. That language is written by the agent. The policy is issued by the carrier. Those are two different documents. Additional insured status requires a carrier-issued policy endorsement.
What to require from the sub's broker: An endorsement form number confirming additional insured status. For construction, require both CG 2010 (ongoing operations — while the sub is actively on site) and CG 2037 (completed operations — claims that arise after the work is done, such as a defect discovered a year later). Some brokers issue these under blanket additional insured endorsements; confirm the form number covers both scopes.
What to tell a sub when they push back on this: Their broker already has the ability to add additional insured endorsements — it is a standard policy modification, not an unusual request. It may add a small premium, typically absorbed by the sub as a cost of doing business. If the sub's policy cannot accommodate an additional insured endorsement, that is a coverage limitation their broker needs to address — not something the GC can waive.
For the GC admin: When you receive a COI with additional insured language in the Description of Operations but no endorsement form number, ask for the endorsement form numbers (CG 2010, CG 2037, or blanket equivalent) before filing the certificate. That question — "can you provide the endorsement form numbers?" — quickly reveals whether the endorsement is on the policy or only on the certificate.
Primary and noncontributory endorsement — why GCs require it and what it means for subs
The primary and noncontributory endorsement (also written as primary and non-contributory) determines which insurer responds first when a claim involves both the GC's policy and the sub's policy — as most job site liability claims do.
Without a primary and noncontributory endorsement on the sub's policy, both insurers may attempt to share the loss, dispute which policy is primary, or each argue the other should respond first. This delays claims resolution and can result in the GC's own policy being drawn on for a loss caused by their sub's work.
Primary means the sub's policy responds before the GC's policy. Noncontributory means the sub's insurer cannot seek contribution from the GC's insurer — the sub's policy absorbs the full loss up to its limits before the GC's policy is triggered at all. The endorsement must appear on the policy itself, not only in the Description of Operations box on the certificate.
What this means in practice for GCs and subs:
For the GC
Require primary and noncontributory language in your subcontract and verify it appears in the Description of Operations or on an endorsement. If it is missing, your own policy may be drawn into a loss your sub caused.
For the sub
When your broker calls to ask about the primary/noncontributory requirement, it is a standard endorsement request — not unusual language. If your policy does not already carry this provision, ask your broker to add it. It is typically not a coverage change, only an order-of-payment clarification.
For the admin reviewing the COI
A notation in the Description of Operations box is not sufficient. Like additional insured status, primary and noncontributory language must be endorsed on the policy to be enforceable by the carrier. Ask for the endorsement form number.
Waiver of subrogation in construction
Subrogation is an insurer's right to sue a third party that caused — or contributed to — a loss the insurer paid. On a construction job site, that third party is often the GC.
Without a waiver of subrogation: a sub's worker is injured. The sub's WC insurer pays the claim. The insurer's attorneys then identify GC negligence that contributed to the injury — a wet floor, an unsecured ladder, a supervisor who failed to enforce PPE requirements. The insurer files suit against the GC to recover what they paid. The GC's own GL policy now has to defend them against their own sub's insurer.
A waiver of subrogation endorsement prevents this. The sub's insurer agrees in advance to waive the right to pursue the GC after paying a claim — even if the GC was partially at fault.
For the sub: A waiver of subrogation endorsement often carries an additional premium — typically a small percentage of the total policy cost. It is a normal request on commercial construction projects. The sub's broker handles the endorsement; the sub does not need to understand the mechanics of subrogation to get it done. They simply need to know that their GC contract requires it and pass that requirement to their broker.
For the GC admin: Require the waiver of subrogation on GL, WC, and umbrella in your subcontract language. Verify it appears in the Description of Operations or on an attached endorsement page — not just in your contract. A contract that requires a waiver of subrogation does not bind the insurer; the endorsement on the policy does.
Sample letter requesting a COI from a subcontractor
Use this as a starting template. Fill in the bracketed fields for each sub and project. Send it before mobilization — not after the sub has already started work.
COI Request Letter Template
Subject: COI Required Before Mobilization — [Project Name]
[Sub Company Name],
Before mobilization on [Project Name] at [Project Address], please provide a current certificate of insurance meeting the requirements below. We cannot authorize work to begin until a compliant certificate is on file.
CERTIFICATE HOLDER
Please list the following as certificate holder:
[Your Company Legal Name]
[Your Company Address]
REQUIRED COVERAGES AND MINIMUM LIMITS
• Commercial General Liability (occurrence form)
– Per occurrence: $[X,000,000]
– General aggregate: $[X,000,000]
– Products/completed operations aggregate: $[X,000,000]
• Workers' Compensation: Statutory limits
• Employer's Liability: $1,000,000 each accident
• Commercial Auto Liability: $1,000,000 combined single limit
• Umbrella/Excess Liability: $[X,000,000] (follow-form)
REQUIRED ENDORSEMENTS
The following endorsements must appear on the policy and be referenced by endorsement form number on the certificate or attached endorsement pages:
1. Additional Insured — Ongoing Operations (CG 2010 or equivalent)
Named as additional insured: [Your Company Legal Name] and [Owner Name, if required]
2. Additional Insured — Completed Operations (CG 2037 or equivalent)
Named as additional insured: [Your Company Legal Name] and [Owner Name, if required]
3. Primary and Noncontributory — the above policies are primary and noncontributory with respect to any insurance maintained by [Your Company Legal Name]
4. Waiver of Subrogation — in favor of [Your Company Legal Name] on all required policies (GL, WC, umbrella)
DESCRIPTION OF OPERATIONS
Please include the following in the Description of Operations field:
"[Project Name] located at [Project Address]. [Your Company Legal Name] and [Owner Name] are included as additional insured per endorsements CG 2010 and CG 2037. Coverage is primary and noncontributory. Waiver of subrogation applies."
Please direct your broker to issue the certificate to the address above and send a copy to [admin email]. If your current policy does not include these endorsements, please contact your broker to have them added before submitting.
Questions? Contact [Admin Name] at [phone] or [email].
[Your Name]
[Your Title]
[Your Company]
Tip: Customize the minimum limits for each project based on your prime contract's insurance exhibit. A residential remodel has different minimums than a $10M commercial build. Sending the same template with the same limits to every sub creates compliance gaps when project requirements vary.
What to do when a sub's COI doesn't meet requirements
The most important rule: do not accept a deficient certificate and file it. An accepted certificate — even a deficient one — becomes the documented evidence of what the GC required. If you accept a COI with $500K GL when your contract requires $1M, you have established that $500K was sufficient for this sub on this project.
1
Return it with specific line items, not general feedback
Don't send back "this doesn't meet our requirements." Send back exactly what is wrong: "Limits are $1M/$2M — we require $2M/$4M. Additional insured endorsement form number is missing. Waiver of subrogation not referenced." The more specific you are, the faster the sub's broker can make corrections.
2
Set a 48-hour deadline and hold it
Subs and their brokers can produce a corrected certificate within 24 hours in most cases. Give them 48 hours and communicate that work cannot start until the corrected certificate is on file. A deadline with no consequence is not a deadline.
3
Do not let work begin until requirements are met
This is the hard part. A sub shows up on Monday and the certificate isn't right. Letting them start "just for today" while you sort it out is how coverage gaps happen. If the sub starts work without a compliant COI and something goes wrong, your exposure is exactly the same as if you never collected a COI at all.
4
Document the exchange in writing
Email, not a phone call. If a deficiency is later disputed — by the sub, by an owner's risk manager, or in litigation — you need a record showing what was deficient, when you notified the sub, and when a compliant certificate was received. A paper trail is your protection.
5
Re-verify when the corrected certificate arrives
Run through the same checklist. Subs occasionally send a second certificate that fixes one item and introduces a new error. The most common: corrected limits but the additional insured endorsement number still missing, or a new expiration date that has already passed.
How to track COI renewals across your sub roster
Most subcontractor policies renew annually — but not on the same date. A sub who started work in February has a policy that may expire in February, while a sub who started in August expires in August. A sub you haven't used in six months may have let their policy lapse without telling you. You won't know until you check — or until there's a claim and their insurer denies coverage because the policy wasn't active.
The tracking problem compounds with roster size. Five active subs is manageable with a spreadsheet. At thirty subs across five projects — some recurring, some new, all with different GL and WC renewal dates — the manual tracking process breaks down in predictable ways:
Expiration dates get logged once and never updated. The admin records the expiration at collection and moves on. No one checks again until the sub shows up for a new project months later.
GL, WC, and umbrella often renew at different times. A spreadsheet with a single expiration date per sub misses two of the three renewal events.
Renewal reminders require manual effort. Someone has to remember to check the spreadsheet 30 days before each expiration date, find the sub's contact, and send a request. When that person is sick, on vacation, or just busy, it doesn't happen.
Recurring subs get less scrutiny. A sub you've worked with for three years feels like a known quantity. Their insurance has always been fine. Until it isn't — and no one checked because the relationship felt established.
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Frequently Asked Questions
Do subcontractors need a separate COI for each project?
Not a separate policy — but a project-specific certificate. A sub's underlying insurance policy can cover multiple projects, but the COI issued to the GC should reference the project address, name the GC (and often the owner) as additional insured, and include required endorsements. A generic certificate naming the agent as certificate holder does not satisfy these requirements. The sub's broker issues an updated certificate for each GC or project that requires one — which is a routine request that takes minutes.
Can a sub add me as additional insured on the certificate without calling their broker?
A sub can write anything in the Description of Operations box on the ACORD 25 — but that text does not modify the policy. Additional insured status requires a policy endorsement issued by the carrier. The sub must contact their broker, who requests the endorsement from the carrier. The endorsement form numbers (CG 2010 for ongoing operations, CG 2037 for completed operations) confirm the endorsement exists on the policy, not just on the certificate.
What if a sub is a sole proprietor — do they still need workers' compensation?
It depends on the state. In most states, sole proprietors in construction are either required to carry workers' compensation or can opt out with a formal waiver. Texas is unusual in that WC is elective for all employers. Even where a sole proprietor can opt out, require documentation of their exempt status — because if an uninsured sub is injured on your site, the liability exposure shifts to the GC. The safest practice is to require WC contractually for every sub regardless of state exemptions.
What's the difference between "primary and noncontributory" on the certificate vs. on the policy?
A notation in the Description of Operations box stating "primary and noncontributory" is written by the insurance agent and does not bind the carrier. For this language to be enforceable, it must be added to the policy by endorsement. If it is missing from the policy and a claim is filed, both the sub's insurer and the GC's insurer may dispute which policy responds first — potentially drawing the GC's own policy into a loss their sub caused.
How long should I keep a sub's COI after the project ends?
Keep construction COIs for at least as long as your state's statute of limitations for construction defect claims — typically three to ten years. In California, latent defect claims run ten years from substantial completion. In Texas, the general limitations period is ten years. In Florida, latent defect claims run ten years. Completed operations claims can surface years after a project closes — the COI on file is your documentation of the sub's coverage at the time of work.
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