Subcontractor COI Checklist: What GCs Must Verify Before Work Begins

General contractors face significant liability exposure from the subcontractors they hire. A sub's employee injured on your job site, a completed-operations claim arising from a sub's work years later, a property damage event caused by a sub during construction - these losses can and do become the GC's liability when the sub is uninsured or underinsured.

This checklist covers what to verify on every subcontractor COI before work begins.

Commercial General Liability

• Coverage type: "Commercial General Liability" on occurrence form (not claims-made for most construction work)
• Per occurrence limit: Meets or exceeds your subcontract requirement (commonly $1M-$2M)
• General aggregate limit: Meets your requirement (commonly $2M-$4M); confirm whether aggregate is per-policy or per-project
• Products/Completed Operations aggregate: Present and meets your requirement - this covers claims arising after the sub's work is done
• Personal and Advertising Injury: Present
• Named insured: Matches exactly the legal entity name in your subcontract - LLC vs. Inc., spelling, middle words
• Policy dates: Effective date is on or before project start; expiration is on or after project completion (or ongoing monitoring for multi-year projects)
• Additional insured (AI): CG 20 10 (ongoing operations) and CG 20 37 (completed operations) confirmed via endorsement or description of operations language
• Primary and non-contributory: Confirmed - the sub's policy responds first, before your own GL
• Waiver of subrogation: Confirmed on GL
• Per-project aggregate endorsement: For large projects, verify the aggregate isn't depleted by other projects the sub is working on simultaneously

Workers' Compensation / Employer's Liability

• Workers' comp coverage: Present for the states where the sub will be performing work
• Employer's liability limits: Meet your requirement (commonly $500K-$1M each accident/disease)
• Waiver of subrogation: WC 04 03 A or equivalent confirmed - prevents the sub's WC carrier from suing you if they pay a claim involving a condition on your site
• Stop-gap coverage: Required if the sub will work in a monopolistic WC state (ND, OH, WA, WY) where WC coverage comes from the state fund, not a private carrier

Commercial Auto Liability

• Coverage type: "Any Auto" is preferred; "Scheduled Autos + Hired/Non-Owned" is acceptable if the sub owns no vehicles but uses hired or employee vehicles on the project
• Combined single limit: Meets your requirement (typically $1M)
• Additional insured: Confirm AI on auto if your contract requires it

Umbrella / Excess Liability

• Limit: Meets your contract requirement (commonly $5M-$25M depending on project size)
• Follows form: Umbrella/excess policy follows form over GL, WC, and auto - meaning it applies to the same coverage lines
• Schedule of underlying: Verify the underlying policy limits on the umbrella declaration match the limits on the underlying policies listed on the ACORD 25
• AI and WOS: Confirm these flow through to the umbrella if your contract requires it

Professional Liability (If Applicable)

Required for: design-build subcontractors, engineers, architects, specialty consultants (geotechnical, environmental, commissioning), and any sub whose work has a significant design or professional component.

• Policy type: Professional liability (E&O) or design professional liability
• Per claim / aggregate limits: Meet your requirement (typically $1M-$5M)
• Retroactive date: For claims-made policies, verify the retroactive date covers the period of relevant prior work
• Extended reporting period: Understand what happens to coverage after policy expiration

Builders Risk (If Applicable)

Builders risk is typically carried by the GC or owner under a project policy or course-of-construction policy. However, verify:

• If the sub carries their own installation floater for their materials and equipment on site
• Whether the sub's tools and equipment are covered (often by an inland marine "tools and equipment" policy)
• Whether the project-level builders risk policy covers all subs or whether subs need their own coverage for certain items

Named Insured Verification

This is the most commonly overlooked check: the entity on the COI must match the entity in your subcontract.

• Legal entity name is identical (not similar - identical)
• State of formation matches (if you have reason to verify)
• If the sub is doing business under a trade name, confirm the policy covers the trade name or that the legal entity is the contracting party

Common problem: a sub does business as "Apex Electrical" but the legal entity is "Apex Services LLC." The subcontract is with "Apex Electrical." The COI shows "Apex Services LLC." These don't match - and coverage may not apply if a claim is made against "Apex Electrical."

Description of Operations

• Your organization and any required upstream parties (owner, lender) are named as additional insured
• Project name or address is referenced if your contract requires it
• Any special endorsement language required by your contract or your owner appears here

Documentation Requirements

• COI verified before the sub begins work (not after)
• Verification recorded: who verified, when, what was checked
• Copy of AI endorsement forms on file for high-risk subs
• Expiration date logged and renewal request scheduled for 45-60 days out

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