# A certificate is not coverage: six ways contractor COIs fail project requirements

White paper R-01, COI Journal Resource Center. The certificate is the one document everyone collects and almost nobody can rely on by itself. Here is where it breaks, in the order we would check it.

By The editors, COI Journal. November 13, 2026. Docket COIJ-26-0002. Published by Forsured.

## Key findings

- The ACORD 25 says on its face that it "confers no rights upon the certificate holder." Rights come from the policy and its endorsements.
- Most failures fall into six patterns: a missing endorsement, no completed operations coverage, a shared aggregate, the wrong priority or subrogation terms, coverage that changes after the certificate is issued, and coverage that isn't what it appears to be.
- Every one of the six can be checked before work starts, with documents the contractor's broker can supply.
- Nobody publishes how often each failure happens. That is the question the COI Gap Index is built to answer.

## The document everyone collects

On almost every construction project, a general contractor asks each trade for a certificate of insurance before work starts. The certificate goes in a folder or a spreadsheet, a box gets ticked, and the job moves on.

The certificate is useful. It tells you who the contractor's broker is, which carriers write the policies, the policy numbers, the dates and the limits. What it can't do is prove that the coverage your project requirements ask for actually exists.

The form says so itself. The current ACORD 25, the standard certificate of liability insurance, opens with this line: "This certificate is issued as a matter of information only and confers no rights upon the certificate holder." It adds that the certificate "does not affirmatively or negatively amend, extend or alter the coverage afforded by the policies below."

Then comes the box most people skip. "IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions" or be endorsed. The same box says that if subrogation is waived, "certain policies may require an endorsement."

Read together, those lines tell you how to treat every certificate you collect. It is a summary of coverage, written by the contractor's broker. It is a pointer to the documents that matter, not a substitute for them.

## Failure 1: the box is checked, the endorsement isn't there

The ADDL INSD column on the certificate has room for a single letter. A Y in that column is a statement that additional insured status exists. It is not the endorsement that creates it.

Additional insured status comes from an endorsement to the contractor's general liability policy. The common ISO forms are CG 20 10 for ongoing operations, CG 20 37 for completed operations and CG 20 38 for the wider contract chain. Carriers also write their own versions. Many are blanket endorsements, which give additional insured status to anyone the contractor agreed in writing to add, so whether you qualify can turn on what your subcontract says and when it was signed.

**What to check.** Ask for a copy of the endorsement, not just the certificate. Confirm that it names you, or that its blanket wording fits your written contract. Confirm that it covers the kind of work the trade is doing on your project. See [additional insured](https://coijournal.com/dictionary/additional-insured/) in the COI Dictionary.

## Failure 2: covered during the job, not after it

An ongoing operations endorsement protects you while the trade is working. Many construction claims arrive later, after the work is finished and the trade has left the site: a leak, a collapse, a defect that shows up a season or two on.

Those claims fall under completed operations. If the contractor's policy extends additional insured status only for ongoing operations, the certificate can look perfect and still leave you with nothing once the job closes out. Project requirements often say how many years after completion the coverage has to stay in place.

**What to check.** Look for a completed operations endorsement, CG 20 37 or the carrier's equivalent, alongside the ongoing operations one. Compare how long it lasts with what your requirements ask for. See [completed operations](https://coijournal.com/dictionary/completed-operations/).

## Failure 3: the limit is real, but it's shared

A certificate shows a general aggregate limit, the most the policy will pay in a policy period. Unless the policy says otherwise, that aggregate is shared across every job the contractor works that year. A large claim on someone else's project can use up the limit your project was counting on.

A per project aggregate endorsement, CG 25 03 in the ISO program, gives each project its own aggregate. The certificate may or may not mention it.

**What to check.** If your requirements call for a per project aggregate, ask for the endorsement. See [per project aggregate](https://coijournal.com/dictionary/per-project-aggregate/).

## Failure 4: who pays first, and who can come after you

Two more requirements show up in most construction contracts and are easy to miss on a certificate.

Primary and noncontributory wording means the contractor's policy pays before yours, and doesn't ask your policy to share the loss. It is usually granted by endorsement, CG 20 01 in the ISO program. A waiver of subrogation means the contractor's carrier gives up the right to recover what it paid from you. On general liability that is often CG 24 04, and on workers' comp WC 00 03 13. The ACORD 25 itself warns that a waiver may require an endorsement.

**What to check.** Confirm that each endorsement exists on each policy your requirements name. A waiver on the general liability policy does nothing for a workers' comp claim if the workers' comp policy doesn't carry its own. See [primary and noncontributory](https://coijournal.com/dictionary/primary-and-noncontributory/) and [waiver of subrogation](https://coijournal.com/dictionary/waiver-of-subrogation/).

## Failure 5: true on the day it was issued

A certificate describes coverage on the day the broker prints it. Policies expire, get cancelled for nonpayment, or get rewritten at renewal with different endorsements. None of that changes the paper in your file.

The cancellation box on the ACORD 25 says notice of a cancellation "will be delivered in accordance with the policy provisions." That is a reference to whatever the policy says, not a promise that you will be told. Many policies only notify the named insured.

**What to check.** Keep track of every expiration date. Ask for the renewal certificate and endorsements before the old policy ends, not after. Check again before final payment and before releasing retainage. See [notice of cancellation](https://coijournal.com/dictionary/notice-of-cancellation/).

## Failure 6: coverage that isn't what it appears to be

The first five failures are gaps between what a certificate shows and what a policy says. The sixth is worse: the coverage behind the certificate doesn't match the risk on your site at all. Three stories from 2026 show how.

In Florida, authorities charged seven people in what [Insurance Journal reported](https://www.insurancejournal.com/magazines/mag-features/2026/09/07/883922.htm) as an alleged $100 million workers' comp scheme. Prosecutors say shell companies bought thin coverage by underreporting payroll, then rented their certificates to subcontractors whose crews were paid in cash. In that scheme, a genuine certificate could sit on top of a policy that was never meant to cover the people on the job.

Also in Florida, a federal grand jury indicted two men tied to two companies that were not licensed to write property and casualty coverage in the state, [according to Insurance Journal](https://www.insurancejournal.com/news/southeast/2026/10/29/890770.htm). Prosecutors allege the pair collected more than $651,000 in premiums and issued falsified certificates. Both have pleaded not guilty.

In Illinois, an appellate court ruled that a general liability carrier owed no indemnity after a carpenter was killed on a hotel site, because the policy's employee injury exclusion applied and the contractor had no workers' comp in force, [Business Insurance reported](https://www.businessinsurance.com/insurer-prevails-in-coverage-dispute-over-carpenters-death/). General liability policies usually exclude injuries to the contractor's own employees. That is what workers' comp is for.

**What to check.** Confirm that the carrier named on the certificate is licensed in your state, through your state's insurance department or the NAIC's [Consumer Insurance Search](https://content.naic.org/cis_consumer_information.htm). Confirm that workers' comp is actually in force for the company whose crew is on your site, and check whether your state offers a proof of coverage lookup. Make sure the named insured on the certificate is the same company that signed your subcontract.

## A checking order that works

None of these checks is exotic. The hard part is doing all of them, for every trade, every time a policy renews. This is the order we'd work in.

1. Write the project requirements down, per trade, before you collect anything.
2. Read each certificate against those requirements, line by line, not against a generic checklist.
3. Ask for the endorsements behind every requirement the certificate claims to meet.
4. Check the carrier's license and the named insured.
5. Diary every expiration date and ask for renewals before they hit.
6. Check again at renewal, at substantial completion and before final payment.

## What we don't know yet

This paper describes how certificates fail. It doesn't say how often. As far as we can find, nobody publishes a reliable answer: how many contractor certificates fail at least one project requirement, which requirements fail most and how long a fix takes.

That is the question the COI Gap Index is built to answer. It will run only when the sample is big enough to be honest, with the sample size printed next to every number. Our [methodology](https://coijournal.com/methodology/) explains the rules. If you're a construction broker, you can [join the broker panel](https://coijournal.com/methodology/#panel-h).

## How we wrote this

This is a qualitative paper. It draws on the text of the current ACORD 25 form, the standard ISO endorsement numbers listed in the COI Dictionary, and 2026 reporting by Insurance Journal and Business Insurance. It contains no survey data and no estimates of how often each failure occurs. Where a case is still in court, we report the allegations as allegations.

## Sources

- [ACORD 25 Certificate of Liability Insurance (2025/12), as posted by the New York State Department of Financial Services](https://www.dfs.ny.gov/system/files/documents/2025/12/acord-25-2025-12-liability.pdf), ACORD / NY DFS
- [Seven Charged in $100 Million Workers' Comp Fraud in Florida](https://www.insurancejournal.com/magazines/mag-features/2026/09/07/883922.htm), Insurance Journal, September 7, 2026
- [Insurer prevails in coverage dispute over carpenter's death](https://www.businessinsurance.com/insurer-prevails-in-coverage-dispute-over-carpenters-death/), Business Insurance, October 2, 2026
- [Florida Men Charged With Creating Sham Insurance Now Face Federal Indictment](https://www.insurancejournal.com/news/southeast/2026/10/29/890770.htm), Insurance Journal, October 29, 2026
- [Consumer Insurance Search](https://content.naic.org/cis_consumer_information.htm), National Association of Insurance Commissioners