A COI in the oil and gas industry carries more weight - and more complexity - than in almost any other sector. The standard ACORD 25 form was designed for commercial real estate and light-risk contracting. Upstream oil and gas has coverage types, endorsement requirements, and policy form provisions that the ACORD 25 barely captures.
An oilfield COI that "looks right" may still be missing pollution retroactive dates, umbrella follow-form confirmation, control of well coverage for the specific operation type, or XCU exclusion removal. These gaps don't appear on the certificate face - and they represent the most financially significant coverage failures in the industry.
What the ACORD 25 Captures (and What It Doesn't)
The ACORD 25 form provides check boxes and limit fields for the most common commercial insurance lines. For oil and gas, this creates systematic blind spots:
What the COI shows:
- Coverage types present (GL, auto, WC, umbrella, pollution - if listed)
- Policy limits for each line
- Insurer name and policy number
- Effective and expiration dates
- Certificate holder and additional insured (description field only)
What the COI does NOT show:
- Whether GL policy XCU exclusions have been removed
- Pollution policy form (occurrence vs. claims-made)
- Pollution policy retroactive date
- Whether umbrella follows form over all required lines
- Whether umbrella policy excludes pollution
- Whether control of well covers the specific operation type
- Maritime endorsements (USL&H, Jones Act)
- Whether additional insured is named on the pollution policy (not just GL)
Every item in the "does not show" list requires verification beyond the certificate.
Required Coverage Types on an Oilfield COI
General Liability (With XCU Confirmation Required)
| Field | What to Check |
|---|---|
| Each occurrence limit | Must meet MSA minimum (typically $1M-$2M) |
| General aggregate | Minimum 2x per-occurrence limit |
| XCU exclusions | Must be confirmed removed - not visible on COI face |
| Products/completed ops | Included and meets MSA minimum |
The XCU check cannot be done from the COI alone. Request the GL policy declarations page or a letter from the agent confirming XCU exclusions are not in force.
Pollution Liability
| Field | What to Check |
|---|---|
| Limit | Meets MSA minimum (typically $1M-$5M) |
| Form | Occurrence or claims-made (claims-made requires retroactive date review) |
| Retroactive date | Must predate start of contractor work on the asset |
| Extended reporting period | Confirm availability if claims-made |
| Coverage scope | Confirm covers hydrocarbons, produced water, drilling fluids |
Control of Well (If Required by MSA)
| Field | What to Check |
|---|---|
| Limit | Must meet MSA minimum and be calibrated to well type |
| Coverage scope | Re-drilling, seepage/pollution, third-party liability |
| Territory | Must cover the location of operations |
Control of well coverage is often listed in the "Additional Coverage" or description-of-operations section of the ACORD 25 - it does not have a standard checkbox on the form.
Umbrella / Excess Liability
| Field | What to Check |
|---|---|
| Limit | Meets MSA minimum (typically $5M-$25M) |
| Follow-form | Confirm it follows form over GL, auto, and employers' liability |
| Pollution exclusion | Umbrella must not exclude pollution if the MSA requires umbrella to sit over pollution |
| Self-insured retention | Note any SIR that reduces effective coverage |
Workers' Compensation and Employers' Liability
| Field | What to Check |
|---|---|
| WC statutory limits | Confirmed for all states of operation |
| All States endorsement | Required for multi-state operations |
| Employers' liability | $1M/$1M/$1M minimum for oilfield operations |
| USL&H | Required if any maritime exposure (offshore, near-shore, vessels) |
| Jones Act | Required for seamen |
Reading the COI Description-of-Operations Field
In oilfield COIs, the description-of-operations field carries more information than in other industries. It should include:
- Reference to the specific MSA or contract
- Confirmation of additional insured status (all policies, not just GL)
- Confirmation of waiver of subrogation (all policies, including WC)
- Any special endorsements required by the MSA (cross-liability, XCU removal, etc.)
- Operator's entity name as additional insured
A description-of-operations field that says only "operations as required by contract" is insufficient. Require the specific language your MSA specifies.
Step-by-Step Oilfield COI Verification Process
Step 1: Pull the MSA insurance exhibit and list every required coverage, limit, and endorsement.
Step 2: Compare the COI face to the list - checking coverage types and limits.
Step 3: Request GL policy declarations or agent letter confirming XCU exclusions removed.
Step 4: For pollution coverage, verify form type, retroactive date, and coverage scope with the agent.
Step 5: For umbrella coverage, request umbrella declarations to verify follow-form status and confirm no pollution exclusion.
Step 6: Verify additional insured endorsements are on the policy - call the agent for each required policy (GL, auto, umbrella, pollution).
Step 7: Verify waiver of subrogation on all policies including workers' compensation.
Step 8: For offshore or maritime operations, confirm USL&H and/or Jones Act endorsements.
Step 9: Document the review with dates, findings, and any gaps requiring remediation.
Frequently Asked Questions
Why do oilfield operators require pollution coverage when contractors don't handle chemicals? Even contractors who don't work directly with chemicals can cause pollution events - a fuel spill from equipment, a hydraulic fluid release, disturbed soil contamination. Additionally, "pollution" in oil and gas contexts includes produced water, drilling mud, and hydrocarbons from the wellbore itself. Any contractor working on or near a producing well has pollution exposure.
What's the difference between occurrence and claims-made pollution coverage? Under an occurrence form, coverage applies to incidents that happen during the policy period regardless of when the claim is filed - even years later. Under a claims-made form, coverage applies only to claims filed while the policy is in force. Claims-made policies require careful retroactive date management; a gap in the retroactive date can leave past incidents uninsured.
Can a contractor satisfy pollution requirements through a wrap-up or OCIP? Some operators run owner-controlled insurance programs (OCIPs) or contractor-controlled programs (CCIPs) that provide pollution coverage for all enrolled contractors. If a contractor is enrolled in such a program, they may not need a separate pollution policy. However, the program terms must specifically cover the work scope and site - and the contractor must provide documentation of enrollment.
Why does the additional insured requirement extend to the pollution policy? Because when a contractor causes a pollution event on an operator's asset, the operator is frequently named as a co-defendant in regulatory actions and third-party lawsuits. Additional insured status on the pollution policy allows the operator to access the contractor's pollution coverage to defend and indemnify. Without it, the operator faces those claims with only their own assets.
A certificate of insurance in the oil and gas industry is a starting point, not an ending point. The coverage details that matter most - XCU removal, pollution retroactive dates, umbrella follow-form - require verification beyond the ACORD 25 face.
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