Subcontractor COI Tracking for Small GCs: A Plain Guide

Subcontractor COI tracking means three things: get a certificate of insurance from every sub before they start, check it against the insurance section of your subcontract, and chase the renewal before any policy on it expires. A certificate is only a summary. The standard ACORD 25 form says it "is issued as a matter of information only and confers no rights upon the certificate holder," so if your subcontract requires additional insured status or a waiver of subrogation, ask for the endorsements too. For a GC with a few dozen subs, a well-kept spreadsheet and a calendar reminder can do the job.

What a certificate of insurance is

IRMI defines a certificate of insurance as "a document providing evidence that certain general types of insurance coverages and limits have been purchased by the party required to furnish the certificate." In US construction it is almost always the ACORD 25, one page, issued by the sub's insurance agent or broker.

It lists:

• The insured (your sub) and the producer (their agent).
• Each policy: general liability, auto, umbrella or excess, workers compensation and employer's liability.
• Policy numbers, effective and expiration dates, and limits.
• Two narrow columns marked ADDL INSD and SUBR WVD.
• A description box, where project names and special wording go.
• The certificate holder: you.

Read the fine print at the top. The form says the certificate "does not affirmatively or negatively amend, extend or alter the coverage afforded by the policies below," and the coverage block adds that "limits shown may have been reduced by paid claims." The certificate tells you what existed on the day it was printed. It does not tell you the policy is still in force next month.

Additional insured, in plain words

IRMI: an additional insured is "a person or organization not automatically included as an insured under an insurance policy who is included or added as an insured under the policy at the request of the named insured." In a subcontract, you ask to be added to the sub's liability policy, usually alongside an indemnity clause. IRMI notes that additional insured status "is viewed by most indemnitees as a way of backing up the promise of indemnification."

The certificate's ADDL INSD box is not the same as being added. The ACORD 25 header is direct: "If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed... A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s)."

That is why published GC requirements ask for the endorsement itself. Pepper Construction's subcontractor exhibit asks for "A Certificate of Insurance on an ACORD form, and the Additional Insured Endorsement (including a waiver of subrogation)," and names the ISO forms it expects for ongoing and completed operations (CG 20 10 and CG 20 37).

Waiver of subrogation, in plain words

Subrogation is an insurer's right, after it pays a claim, to go after whoever caused the loss. IRMI defines a waiver of subrogation as "an acknowledgment by an insurer that it has no right to subrogate against a liable third party after it has paid a loss on behalf of its insured." In a subcontract it usually means the sub's insurer will not turn around and sue the GC or owner.

IRMI adds a timing point worth knowing: policies generally allow a waiver agreed before a loss, but "coverage is excluded from many policies if subrogation is waived after a loss." Get it in the contract and on the policy before work starts. The ACORD 25 notes that "certain policies may require an endorsement" for the waiver, which is why the SUBR WVD box alone is not proof.

Limits: what published GC exhibits ask for

There is no single standard. Limits depend on the owner contract, the trade and the project. A few published examples, to show the shape rather than a rule:

Published requirement	General liability per occurrence	Umbrella or excess
Pepper Construction, most subs	$1,000,000	$1,000,000
Pepper Construction, "Major Trade" subs (incl. hoisting/tower crane, steel erection)	$2,000,000	$5,000,000
XL Construction, most subs	$1,000,000	as required
XL Construction, "High Risk" subs (incl. cranes)	$2,000,000	as required

Both exhibits also require auto liability and workers compensation with employer's liability, and both set a minimum insurer rating. Your own owner contract usually sets the floor you have to pass down. Ask your broker to read it with you and turn it into a one-page exhibit for your subcontracts. Crane work has its own extras, covered in crane certificate of insurance requirements.

Why expirations are where it breaks

A certificate is accurate on day one. Policies renew on their own schedule, usually once a year, and each policy on the same certificate can expire on a different date. The sub's umbrella might renew in March and their auto in August. A job that runs nine months can easily outlive one of them.

Published requirements push the notice duty onto the sub. Pepper's exhibit says the sub "shall notify PEPPER by email within thirty (30) days if such Certificate is to be altered, cancelled or allowed to expire," and that Pepper will withhold payment until "a properly executed Certificate of Insurance and endorsement" are received. If your subcontract has no clause like that, the tracking has to come from your side.

Your own insurer may ask about it too. The Skyward crane and rigging insurance application asks the applicant: "Does the applicant obtain certificates of insurance from all sub-contractors?", "Is there a Diary System in place to track expiration dates of certificates of insurance?" and "Is the applicant named as additional insured on all sub-contractors' policies?" A "diary system" is just a list sorted by date with someone responsible for it.

A COI tracking spreadsheet that works

If you track in a spreadsheet, one row per policy, not one row per sub, is what makes expirations visible. Columns:

Column	Why
Sub name	Who
Project(s)	Which jobs this certificate covers
Policy type	GL, auto, umbrella, WC/EL, plus riggers or pollution where your contract asks
Insurer and policy number	To match renewals to the right line
Effective date / expiration date	Sort on expiration
Limits shown	Compare to your exhibit
Additional insured endorsement received (Y/N)	The certificate box is not enough
Waiver of subrogation endorsement received (Y/N)	Same
Certificate holder name correct (Y/N)	Wrong entity names are common
Date requested / date received	For the follow-up
Agent email	Renewals usually come from the agent, not the sub

Then two habits: sort by expiration every Monday, and email the agent about 30 days before anything expires. Keep the PDFs in one folder per sub, named with the expiration date.

Spreadsheet, software or prequalification platform

• Spreadsheet: free and fine for a modest sub list if one person owns it. It fails when that person is on vacation or the list passes what anyone can eyeball.
• COI tracking software: dedicated services read certificates, compare them to your requirements and send renewal requests to agents. Usually priced per vendor or per seat. Worth a look when the spreadsheet is late more often than not.
• Prequalification platforms: ISNetworld, for example, lists "insurance certificates, and workers' compensation documents" among what it collects and reviews. Larger owners and GCs often require subs to join one; the sub pays a subscription. See subcontractor prequalification for crane work.

Whichever you choose, the certificate is one item in a longer packet. For crane subs, the rest of the list (annual inspection, operator cards, load chart) is in what to require from a crane subcontractor.

Common certificate problems

• Certificate holder names the wrong legal entity, or an old address.
• ADDL INSD box marked but no endorsement attached.
• Umbrella listed but it does not follow form over auto or employer's liability, when your exhibit says it must.
• Project not named, or a blanket certificate without the wording your contract asks for.
• One policy on the certificate already expired on the day you received it.

None of these needs a lawyer to spot. Each needs someone to read the certificate against the exhibit before the sub mobilizes.

Where CraneFile fits

We're building CraneFile around the crane side of this chase: the crane company keeps its COI, annual inspection and operator cards current in one file and sends the GC a single link, with each document's dates visible. It is not live yet. GCs who want to tell us what they chase subs for can start here; crane shops can get early access or call us at (786) 471-4419.

This is plain-English guidance, not legal or insurance advice. Your contract and the policy wording govern, the regulation text governs any safety rule mentioned, and your broker should review your insurance requirements.

Questions we get

This is plain-English guidance, not legal advice. The regulation text and your state's rules govern.

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