This checklist provides a structured reference for reviewing subcontractor COIs against typical commercial construction subcontract requirements. Your specific subcontract governs - always use the actual subcontract insurance exhibit as the governing document, not a generic checklist.
Work through each section for every subcontractor before approving site access. A single unresolved gap is grounds to hold the sub until remediated.
Section 1: Core Coverage Requirements by Trade
High-Risk Trades (Demolition, Structural Steel, Excavation, Roofing)
| Coverage | Minimum Requirement | COI Shows | Compliant? |
|---|---|---|---|
| GL - each occurrence | $2,000,000 | ___ | ☐ |
| GL - general aggregate | $4,000,000 | ___ | ☐ |
| GL - completed ops aggregate | $4,000,000 | ___ | ☐ |
| Auto liability (CSL) | $1,000,000 | ___ | ☐ |
| Workers' compensation | Statutory | ___ | ☐ |
| Employers' liability (per accident) | $1,000,000 | ___ | ☐ |
| Umbrella / excess | $5,000,000 | ___ | ☐ |
Standard Trades (MEP, Plumbing, Concrete, Framing, Drywall)
| Coverage | Minimum Requirement | COI Shows | Compliant? |
|---|---|---|---|
| GL - each occurrence | $1,000,000 | ___ | ☐ |
| GL - general aggregate | $2,000,000 | ___ | ☐ |
| GL - completed ops aggregate | $2,000,000 | ___ | ☐ |
| Auto liability (CSL) | $1,000,000 | ___ | ☐ |
| Workers' compensation | Statutory | ___ | ☐ |
| Employers' liability (per accident) | $500,000 | ___ | ☐ |
| Umbrella / excess | $2,000,000 | ___ | ☐ |
Lower-Risk Trades (Painting, Finishes, Landscaping, Cleaning)
| Coverage | Minimum Requirement | COI Shows | Compliant? |
|---|---|---|---|
| GL - each occurrence | $500,000 | ___ | ☐ |
| GL - general aggregate | $1,000,000 | ___ | ☐ |
| GL - completed ops aggregate | $1,000,000 | ___ | ☐ |
| Auto liability (CSL) | $500,000 | ___ | ☐ |
| Workers' compensation | Statutory | ___ | ☐ |
| Employers' liability (per accident) | $100,000 | ___ | ☐ |
| Umbrella / excess | Per subcontract | ___ | ☐ |
Design Professionals (Engineers, Architects, Consultants)
| Coverage | Minimum Requirement | COI Shows | Compliant? |
|---|---|---|---|
| GL - each occurrence | $1,000,000 | ___ | ☐ |
| Professional liability / E&O | $1,000,000-$5,000,000 | ___ | ☐ |
| Auto liability (CSL) | $1,000,000 | ___ | ☐ |
| Workers' compensation | Statutory | ___ | ☐ |
| Professional liability retroactive date | Confirm | ___ | ☐ |
Section 2: Endorsement Verification Checklist
| Endorsement | Form Required | Verification Method | Status |
|---|---|---|---|
| Additional Insured - ongoing ops | CG 20 10 or equivalent | Confirm with GL agent | ☐ |
| Additional Insured - completed ops | CG 20 37 or equivalent | Confirm with GL agent | ☐ |
| Primary / Non-Contributory | CG 20 01 or endorsement | Confirm with GL agent | ☐ |
| Waiver of Subrogation - GL | WOS endorsement | Confirm with GL agent | ☐ |
| Waiver of Subrogation - WC | WOS endorsement | Confirm with WC insurer | ☐ |
| Waiver of Subrogation - auto | WOS endorsement | Confirm with auto insurer | ☐ |
| Per-project aggregate (if required) | CG 25 03 or equivalent | Confirm with GL agent | ☐ |
| 30-day cancellation notice | Policy provision | Confirm with insurer | ☐ |
| XCU exclusions removed (demo/excavation) | GL exclusions | Request declarations or letter | ☐ |
Section 3: Administrative Verification Checklist
| Item | Check | Status |
|---|---|---|
| Named insured matches subcontract entity | Exact legal name | ☐ |
| Certificate holder is GC's correct legal entity | Correct name and address | ☐ |
| Policy effective dates confirmed as current | Call insurer if close to expiry | ☐ |
| Insurer AM Best rating A- or better | Verify at ambest.com | ☐ |
| COI requested from agent directly | Not from sub | ☐ |
| Renewal calendar entry created | 60-day advance request | ☐ |
| Review documented with date and reviewer | For audit trail | ☐ |
Section 4: Completed Operations Tracking
Completed operations coverage is the most frequently overlooked element of construction COI compliance. For every subcontractor, track:
| Item | Requirement | Status |
|---|---|---|
| CG 20 37 (or equivalent) in force | Required for all trades | ☐ |
| Duration of completed ops AI coverage | Per subcontract (e.g., 5 years post-completion) | ☐ |
| Renewal COIs confirm continued completed ops coverage | Annual verification | ☐ |
| Project completion date recorded | For coverage period tracking | ☐ |
| Expected completed ops expiration date | Calculate from project completion | ☐ |
Completed operations claims arise years after project completion. Standard commercial GL policies renew annually - and each renewal may or may not maintain prior-project completed operations coverage. Track this separately.
Section 5: OCIP / CCIP Enrollment Tracking
For projects with wrap-up insurance programs:
| Item | Check | Status |
|---|---|---|
| Sub enrolled in wrap-up program | Confirm with program administrator | ☐ |
| Coverages provided by wrap-up identified | GL, WC, builders risk? | ☐ |
| Coverages sub must still provide independently | Auto, professional liability? | ☐ |
| Sub's own COI reflects excluded coverages | No gap for non-wrap-up coverages | ☐ |
| Enrollment documentation on file | Program certificate or enrollment letter | ☐ |
Specialty Coverage Requirements
Certain scopes of work require coverage beyond the standard stack:
| Work Scope | Additional Coverage | Minimum |
|---|---|---|
| Demolition / blasting | XCU removal in GL or standalone blasting liability | Per subcontract |
| Excavation near existing structures | XCU removal; consider professional liability for geo-tech | Per subcontract |
| Design-build / design elements | Professional liability / E&O | $1M-$5M |
| Hazardous material abatement | Contractor's pollution liability | $1M-$5M |
| Work near occupied structures | Higher GL limits; consider pollution | Per risk assessment |
| High-value project (>$20M contract value) | Consider per-project aggregate | Per subcontract |
Red Flags That Require Immediate Follow-Up
- Named insured on COI does not match the subcontract signing entity
- Any required coverage type is absent from the COI
- Any limit is below the subcontract minimum - even by $1
- Expiration date is within 30 days and no renewal COI provided
- AI checkbox checked but form number not specified (CG 20 10/CG 20 37)
- WOS not confirmed on workers' compensation
- Insurer AM Best rating below A-
- COI shows "claims-made" for GL without discussion of retroactive date
- Per-project aggregate required but not confirmed
Frequently Asked Questions
How do I track completed operations coverage over a 5-year post-completion period? The most reliable approach is to require in the subcontract that the sub maintain completed operations coverage for the specified period and provide annual renewal COIs confirming coverage. For high-value or complex projects, consider requiring the sub to purchase a specific completed operations tail policy with a fixed term.
Does this checklist apply to sub-subcontractors? Your subcontract should require first-tier subs to flow down these requirements to their sub-subs. Whether you independently verify sub-sub compliance depends on your contract and risk tolerance. For high-risk scopes, direct verification of sub-subs is worth the effort.
What if an owner imposes higher requirements than this checklist? The owner's requirements, flowed down through the prime contract, govern. Always check the prime contract for insurance requirements and ensure your subcontract exhibit reflects the higher of your standard requirements or the owner's requirements.
How do I handle a sub who claims their insurer doesn't offer a specific endorsement form? If a required endorsement form (e.g., CG 20 37) is not available from the sub's insurer, the sub needs to find an insurer who can provide it. Accepting an "equivalent" form requires review by a risk advisor or attorney who can confirm the alternative form provides materially similar coverage.
This checklist is a starting point. The governing document is always the specific subcontract's insurance exhibit.
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