The COI Trap: Why a Certificate of Insurance Alone Is Not Enough for General Contractors

subcontractor insurance requirements

A certificate of insurance does not satisfy a general contractor’s subcontractor insurance requirements. A COI summarizes the insurance reported for the subcontractor, including policy types, limits, policy dates, and insurers. The policy and its endorsements determine what coverage exists and who has rights under it. 

So, when a general contractor, or GC, tells you it collects a certificate from every sub, ask the important questions ahead of underwriting. What does the subcontract require? Do the subcontractor’s limits meet those requirements? Is additional insured status required? If so, is the proper endorsement in place? An underwriter reviewing the account’s subcontracted exposure will want those answers. The agent should have them first. 

Why Subcontractor Insurance Requirements Matter

Hiring a subcontractor does not move the risk off the GC’s account. If a sub’s crew injures someone or damages property, the claim can still name the general contractor, and the subcontract usually requires the sub to defend and indemnify the GC.

The difference between an insured and an uninsured subcontractor is who pays when the claim arrives. An insured sub turns it over to its carrier, which handles the defense and any settlement within the policy limits. An uninsured sub pays out of its own pocket, and a small trade contractor may not be able to cover a serious injury claim. The claim then works its way back to the GC’s own general liability policy, which generates a loss the GC never expected to carry, a worse loss history, and a harder renewal.

The subcontractor insurance requirement exists for exactly that reason. An indemnity clause obligates the sub to answer for the exposure, and insurance funds the obligation rather than a contractor’s own finances.

Subcontracted work is one of the risk factors underwriters weigh on an artisan contractor account. So, the first thing to confirm on a GC account is whether the client requires subs to carry their own general liability insurance and whether anyone enforces the requirement.

What Does a COI Tell a General Contractor?

A certificate of insurance for subcontractors summarizes insurance information reported on the certificate as of the date it was issued. It does not amend the policy or grant coverage.

The distinction becomes especially important with additional insured status. Naming the GC as a certificate holder does not make it an additional insured. The policy terms must support additional insured status, often through an endorsement. Depending on the wording, an endorsement may name a specific party or extend status to parties the subcontractor has agreed in writing to add.

New York’s Appellate Division, First Department, applied that principle in February 2026. In Itzhak v. Briarwood Insurance Services Inc., the plaintiff attached a certificate of liability insurance to her complaint in support of her claim that she was an additional insured. The court found the certificate insufficient. Citing earlier New York precedent, the court explained that a certificate may serve as evidence of an insurer’s intent to provide coverage, but it is not a contract of insurance or, by itself, conclusive proof that coverage exists. The certificate also stated that it was issued for informational purposes and conferred no rights on the certificate holder.

The case involved damage to a cooperative unit during a renovation, not a subcontractor insurance dispute. But it illustrates the documentation problem for GCs: A COI may say that additional insured coverage is intended, but the policy terms determine whether the GC qualifies for it.

What Should General Contractors Require From Subcontractors?

Requirements vary by project, contract, carrier, and scope of work, so no single limit or endorsement form fits every account. A GC should set its requirements in writing and check each subcontractor’s documents against them.

  • General liability insurance: Confirm the subcontractor carries its own general liability coverage for its operations.
  • Liability limits: Compare the sub’s limits to the amounts the subcontract requires. Limits equal to or greater than the GC’s own requirement keep a large loss from exhausting the sub’s policy and reaching the GC’s.
  • Additional insured status: When the contract calls for it, confirm the endorsement exists and provides what the contract demands, including primary and noncontributory terms where required.
  • Supporting documentation: Collect the certificate and the required endorsements before the sub starts work.

Flow-down provisions bind the subcontractor to terms in the prime contract between the owner and the GC. So, obligations the GC owes an owner need to appear in its subcontracts. Courts read those documents as written, not as the parties assumed them.

The requirements only work if the GC checks the documents before the sub mobilizes. At that point, the GC still controls whether the sub gets on site, so a missing endorsement or a short limit can be corrected as a condition of starting. Once the sub is working and a loss has already occurred, no endorsement can be added after the fact, leaving the GC arguing with a carrier over coverage it assumed it had.

A Standard for General Contractors

Best practice is to set subcontractor insurance requirements in writing, apply them to every sub, verify them before work starts, and keep the documentation. The certificate is one piece of that file, alongside the subcontract, the additional insured endorsement, and any other policy documents the requirements call for. A GC that keeps only certificates has evidence that coverage was reported, not evidence that it meets the contract. 

Placement and renewal are the natural times to test the process. Ask who at the GC reviews certificates and endorsements and whether a sub can get on site before the review is finished. The answers tell the agent and the underwriter how the account handles risk transfer.

Cochrane & Company writes artisan and general contractor risks through its property and casualty binding and brokerage capabilities. If a general contractor client relies on subcontractors, contact Cochrane & Company to discuss general liability options and the contractor’s subcontracted exposure.

About Cochrane & Company

For more than six decades, Cochrane & Company has been proudly at the forefront of the insurance industry. Our experience has enabled us to innovate in powerful ways, reimagining the E&S market, and providing technology solutions that make it easy to do business with us. Licensed in all 50 states, we proudly serve clients across the nation, providing personalized and powerful solutions to help you become an even better partner for your clients. Speak to one of our experienced professionals today by calling (855) 967-0069.

   

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