Subcontractor COI and Endorsement Checklist

Key takeaways

• Review ongoing and completed operations separately when the contract does: in the ISO editions since 2001, CG 20 10 excludes injury or damage after the work is completed or put to its intended use, and CG 20 37 is the separate completed-operations form.
• A certificate records evidence but does not amend a policy; the ACORD 25 form says so on its face, and ACORD's guidance says only an endorsement, rider, or amendment changes coverage.
• Refresh evidence when the work stage, scope, policy, or expiration changes; completed-operations status for a later period has to be carried on each successive policy.

Match evidence to the actual trade

Begin with the subcontractor's trade and scope, not a generic certificate request. A roofing, electrical, excavation, demolition, or finish-trade exposure may create different contract and project questions, as can work at height, hot work, traffic, or occupied-site work.

Use the work-stage selector to keep ongoing operations and completed operations visible. The distinction comes from the forms themselves: since the 2001 editions, ISO's CG 20 10 covers the additional insured only for the named insured's ongoing operations and excludes injury or damage after the work is completed or put to its intended use, while CG 20 37 covers 'your work' included in the products-completed operations hazard. Each is a scheduled endorsement with an edition date (04 13 and 12 19 are current), and since 2013 both apply only to the extent permitted by law, no broader than the contract requires, and for no more than the lesser of the contract-required amount and the policy limit. The tool does not decide which policy period or endorsement applies; it prompts the team to ask.

Sources for this section: New York City Department of Cultural Affairs: CG 20 10 04 13, Additional Insured—Owners, Lessees or Contractors—Scheduled Person or Organization (sample); Independent Insurance Agents of Texas: CG 20 37 04 13, Additional Insured—Owners, Lessees or Contractors—Completed Operations; International Risk Management Institute (IRMI): 2013 ISO Additional Insured Endorsements: Putting the Changes into Context for the Construction Industry (Mark Bell, August 2013); Saxe Doernberger & Vita (SDV Fenchurch): The 2019 ISO Forms: Additions, Revisions, and Pitfalls (December 2019).

Keep certificates and endorsements distinct

A certificate can help document that evidence was supplied on a date, but it does not amend, broaden, or guarantee the underlying policy. The ACORD 25 certificate states that it is issued as a matter of information only, confers no rights upon the certificate holder, and does not amend, extend, or alter the coverage afforded by the listed policies; ACORD's certificate guidance adds that only an endorsement, rider, or amendment to the policy changes coverage. When a contract requires additional-insured, waiver, primary/noncontributory, or completed-operations wording, locate the actual policy or endorsement evidence requested by the parties.

Each of those requests is a different ISO form. Primary and noncontributory wording is CG 20 01, which applies only where the named insured agreed to it in a written contract; the general liability waiver is CG 24 04, under which only the insurer's recovery rights are waived, with separate waiver endorsements for workers compensation (WC 00 03 13) and auto (CA 04 44). Record exceptions rather than silently treating a certificate description as proof of a policy term. Ask the designated insurance reviewer to compare the form, edition, parties, operations, and dates.

Sources for this section: City of Riverside, California: Sample certificate package: ACORD 25 with CG 20 26 04 13, CG 24 04 05 09, CG 20 01 04 13, CA 04 44, and workers compensation waiver endorsements; ACORD: Certificates of Insurance: Frequently Asked Questions; International Risk Management Institute (IRMI): The 2013 Edition of the CGL Policy (Craig Stanovich, March 2013); International Risk Management Institute (IRMI): Subrogation and the CGL Policy (Craig Stanovich, December 2013); City of Sierra Madre, California: Acceptable waiver-of-subrogation endorsements (CG 24 04 and WC 00 03 13 reproduced).

Refresh evidence at each material change

A file can become stale when a policy expires, the subcontractor changes scope, work moves from ongoing to completed operations, a lower tier is added, or the contract is amended. Keep the expiration date and a responsible person visible.

Workers compensation and auto evidence can involve different jurisdictional, ownership, hired/non-owned, and work-arrangement questions. Use this worksheet to flag those questions, not to make a regulatory or coverage conclusion.

Document exceptions and close-out

Before work begins or a payment milestone, compare the contract requirement, evidence received, and written clarifications. If requested wording is unavailable, preserve the exception and the decision-maker rather than marking the item complete; a request for the 1985 edition of CG 20 10, which had no completed-operations exclusion, is a common example of wording most insurers no longer provide.

At close-out, retain completed-operations evidence and the final scope. Completed-operations additional-insured protection for a period after completion exists only while a CG 20 37-type endorsement is attached to each successive policy during that period, so the file should show how the requirement will be carried at each renewal. A checklist result is an administrative record and does not replace the issued policy or a contract review.

Sources for this section: International Risk Management Institute (IRMI): Additional Insured Endorsements—A Potential Minefield—Part 3 (Craig Stanovich, March 2006); International Risk Management Institute (IRMI): Effective Contractual Risk Transfer in Construction (Ann Hickman, March 2021); International Risk Management Institute (IRMI): Questions and Answers on Additional Insured Issues—Part 2 (Jack Gibson, July 2009).

Evidence versus conclusion

Sources for this section: City of Riverside, California: Sample certificate package: ACORD 25 with CG 20 26 04 13, CG 24 04 05 09, CG 20 01 04 13, CA 04 44, and workers compensation waiver endorsements; New York City Department of Cultural Affairs: CG 20 10 04 13, Additional Insured—Owners, Lessees or Contractors—Scheduled Person or Organization (sample); Independent Insurance Agents of Texas: CG 20 37 04 13, Additional Insured—Owners, Lessees or Contractors—Completed Operations; International Risk Management Institute (IRMI): Effective Contractual Risk Transfer in Construction (Ann Hickman, March 2021).

Use the result as a review agenda

• Record the source document or assumption behind each answer.
• Assign unresolved questions to a person and a date.
• Compare the worksheet with the issued policy and current contracts.

Hypothetical: Hypothetical: operations move to close-out

A subcontractor's work is complete, but the contract requires completed-operations evidence for a later period. The team should retain the requirement and ask how the applicable policy and endorsement address the work stage.

Hypothetical: Hypothetical: certificate has an expiration date

The certificate remains in the file after its listed expiration. The practical outcome is a refresh request and a comparison with the current policy evidence, not an assumption that the old certificate remains effective.

Sources

• New York City Department of Cultural Affairs: CG 20 10 04 13, Additional Insured—Owners, Lessees or Contractors—Scheduled Person or Organization (sample) — accessed 2026-10-18; supports the April 2013 edition of CG 20 10: coverage for injury or damage "caused, in whole or in part" by the named insured's acts or omissions in the performance of ongoing operations, the "to the extent permitted by law" and "not broader than required by the contract" provisos, the exclusion for injury or damage after the work is completed or put to its intended use, and the limits paragraph paying the lesser of the contract-required amount and the declarations limit..
• Independent Insurance Agents of Texas: CG 20 37 04 13, Additional Insured—Owners, Lessees or Contractors—Completed Operations — accessed 2026-10-18; supports the April 2013 edition of CG 20 37: coverage for injury or damage "caused, in whole or in part, by 'your work'" at the scheduled location and included in the products-completed operations hazard, with the same "to the extent permitted by law," "not broader than required by the contract," and lesser-of limits provisions as the 2013 CG 20 10..
• City of Sierra Madre, California: Acceptable waiver-of-subrogation endorsements (CG 24 04 and WC 00 03 13 reproduced) — accessed 2026-10-18; supports a public owner's example of the CGL waiver endorsement (CG 24 04, added to the Transfer of Rights of Recovery Against Others to Us condition) and the separate workers compensation waiver endorsement (WC 00 03 13), showing that each line of coverage waives through its own form..
• City of Riverside, California: Sample certificate package: ACORD 25 with CG 20 26 04 13, CG 24 04 05 09, CG 20 01 04 13, CA 04 44, and workers compensation waiver endorsements — accessed 2026-10-18; supports the ACORD 25 certificate's own notice that it is issued as a matter of information only, confers no rights on the certificate holder, does not amend, extend, or alter the policies, and that additional-insured status or a waiver of subrogation requires a policy endorsement; the package also reproduces CG 20 01 04 13, which makes the CGL primary and noncontributory toward other insurance on which the additional insured is a named insured only where the named insured agreed to that in a written contract, and shows that the general liability, auto, and workers compensation waivers are separate endorsements..
• ACORD: Certificates of Insurance: Frequently Asked Questions — accessed 2026-10-18; supports ACORD's statement that a certificate of insurance is not an insurance policy and does not provide, endorse, amend, extend, or alter policy terms; only an endorsement, rider, or amendment to the policy changes coverage, and a reference to a contract on a certificate does not provide coverage..
• International Risk Management Institute (IRMI): 2013 ISO Additional Insured Endorsements: Putting the Changes into Context for the Construction Industry (Mark Bell, August 2013) — accessed 2026-10-18; supports the edition history of the owners/lessees/contractors additional-insured endorsements: the 1985 'arising out of your work' grant with no ongoing/completed distinction, the 1993 'ongoing operations' limitation, the 2001 completed-operations exclusions and the introduction of CG 20 37, the 2004 'caused, in whole or in part' causation standard, and the 2013 'to the extent permitted by law,' 'not broader than required by contract,' and lesser-of limits provisions, with the anti-indemnity-statute background for those changes..
• International Risk Management Institute (IRMI): Additional Insured Endorsements—A Potential Minefield—Part 3 (Craig Stanovich, March 2006) — accessed 2026-10-18; supports the comparison of CG 20 10 07 04 (which excludes injury or damage occurring after the work is completed or put to its intended use) with CG 20 37 07 04 (which provides completed-operations additional-insured coverage), and the observation that CG 20 37 can be difficult to obtain and that the 11 85 edition of CG 20 10 is generally no longer available..
• International Risk Management Institute (IRMI): Questions and Answers on Additional Insured Issues—Part 2 (Jack Gibson, July 2009) — accessed 2026-10-18; supports that a certificate of insurance confers no coverage, that completed-operations additional-insured coverage for a post-completion period requires an endorsement such as CG 20 37 on each successive policy during that period, and that anti-indemnity statutes in some states limit the additional-insured coverage a contract may require..
• International Risk Management Institute (IRMI): The 2013 Edition of the CGL Policy (Craig Stanovich, March 2013) — accessed 2026-10-18; supports that CG 20 01 applies only if the named insured agreed to primary and noncontributory terms in a written contract or agreement, and that its practical effect is to let 'primary and noncontributory' be shown on a certificate because the unendorsed ISO CGL does not use that phrase..
• International Risk Management Institute (IRMI): Subrogation and the CGL Policy (Craig Stanovich, December 2013) — accessed 2026-10-18; supports that the CGL policy's operative wording is the Transfer of Rights of Recovery Against Others to Us condition, that the waiver endorsement is titled Waiver of Transfer of Rights of Recovery Against Others to Us (CG 24 04 05 09), and that under it only the insurer, not the named insured, waives rights of recovery against the scheduled party..
• International Risk Management Institute (IRMI): Effective Contractual Risk Transfer in Construction (Ann Hickman, March 2021) — accessed 2026-10-18; supports that ISO CG 20 10 (ongoing operations) and CG 20 37 (completed operations) are the standard owner/upstream-contractor additional-insured endorsements; that many contractors cannot provide the broader coverage of prior editions, notably the 11 85 edition of CG 20 10; that insurers resist manuscript additional-insured endorsements; and that CG 20 01 makes coverage primary and noncontributory when a written contract requires it..
• Saxe Doernberger & Vita (SDV Fenchurch): The 2019 ISO Forms: Additions, Revisions, and Pitfalls (December 2019) — accessed 2026-10-18; supports the December 2019 ISO revisions: the restated limits wording in the additional-insured endorsements including CG 20 10 and CG 20 37, the new automatic completed-operations additional-insured endorsements CG 20 39 and CG 20 40 and their written-contract condition, and the revised CG 24 04 and new automatic waiver endorsement CG 24 53..
• Occupational Safety and Health Administration: Construction safety and health topics — accessed 2026-09-13; supports Construction hazards and controls should be documented as project facts, not inferred from a generic form..