Why What Is General Liability Commercial Insurance Matters for GC Compliance in 2026
What is general liability commercial insurance? It is a policy that protects businesses against third-party claims for bodily injury, property damage, and personal injury arising from their operations. For general contractors, commercial general liability (CGL) insurance is the foundation of every subcontractor compliance program. Without verified CGL coverage on every sub, you operate one accident away from absorbing a six-figure claim.
This checklist gives you a step-by-step verification framework for reviewing CGL policies. Print it, share it with your project managers, and use it every time a sub submits a certificate of insurance.
Part 1: ACORD 25 Certificate Verification Checklist
The ACORD 25 is the standard form for proving CGL coverage exists. Every box on this form tells you something about the sub's protection level.
Section-by-Section Verification
Certificate holder information.
- Your company name is spelled correctly
- Your company address is accurate
- Project name or number is listed in Description of Operations
Producer (broker) information.
- Broker name and contact information are listed
- Broker is licensed in the state where work is performed
Insured information.
- Named insured matches the entity name on your subcontract
- Business type (LLC, Corp, Partnership) matches contract
- Address matches what you have on file
Commercial General Liability section.
- "Commercial General Liability" box is checked
- "Occur" is selected (not "Claims-Made")
- Policy number is present
- Policy effective date precedes the sub's start date on your project
- Policy expiration date extends beyond expected project completion
- Each Occurrence limit: minimum $1,000,000
- General Aggregate limit: minimum $2,000,000
- Products-Completed Operations Aggregate: minimum $2,000,000
- Personal and Advertising Injury: minimum $1,000,000
- Damage to Rented Premises: minimum $100,000
- Medical Payments: minimum $5,000
Description of Operations box.
- Your company is named as additional insured
- Project name or address is referenced
- Primary and non-contributory language is stated
- Waiver of subrogation language is stated
- No restrictive language limiting coverage to specific operations
Part 2: Minimum Limits by Project Size
Insurance requirements should scale with project risk. Use this table as a baseline, adjusting upward for high-risk trades.
| Project Value | CGL Per Occurrence | CGL Aggregate | Products-Completed Ops | Umbrella/Excess |
|---|---|---|---|---|
| Under $1M | $1,000,000 | $2,000,000 | $2,000,000 | Not required |
| $1M - $5M | $1,000,000 | $2,000,000 | $2,000,000 | $1,000,000 |
| $5M - $25M | $1,000,000 | $2,000,000 | $2,000,000 | $2,000,000 - $5,000,000 |
| $25M - $100M | $2,000,000 | $4,000,000 | $4,000,000 | $5,000,000 - $10,000,000 |
| Over $100M | $2,000,000 | $4,000,000 | $4,000,000 | $10,000,000+ |
Trade-specific adjustments. High-risk trades warrant higher limits regardless of project size.
- Demolition: add $2M to umbrella minimum
- Structural steel erection: add $2M to umbrella minimum
- Roofing: add $1M to umbrella minimum
- Excavation and foundation: add $1M to umbrella minimum
- Mechanical/HVAC: standard limits typically sufficient
- Electrical: standard limits typically sufficient
- Finish trades (paint, flooring, trim): standard limits typically sufficient
Part 3: Required Endorsements Checklist
Endorsements modify the base CGL policy. Without the right endorsements, a sub's coverage may not protect you at all.
Must-Have Endorsements
Additional insured for ongoing operations.
- CG 20 10 or equivalent is attached
- Edition date is 2004 or earlier (broader coverage) or acceptable alternative
- Coverage trigger is "arising out of" the sub's work, not limited to "caused by"
Additional insured for completed operations.
- CG 20 37 or equivalent is attached
- No time limitation shorter than your state's statute of repose
- Coverage extends to the GC for claims arising after work completion
Primary and non-contributory.
- CG 20 01 or equivalent is attached
- Language states the sub's policy is primary and your policy is non-contributory
- No conditions that must be met before primary status applies
Waiver of subrogation.
- CG 24 04 or equivalent is attached
- Waiver applies in favor of the certificate holder (you)
- No conditions or limitations on the waiver
Nice-to-Have Endorsements
Per-project aggregate (CG 25 03). Dedicates the full aggregate to your project instead of sharing it across all the sub's projects. Particularly valuable for large or long-duration projects.
Designated construction project general aggregate limit. Similar to per-project aggregate but specific to a named project. Ask for this on projects over $10M.
Contractual liability preservation. Ensures the sub's CGL covers liabilities assumed under the subcontract's indemnification clause.
Part 4: Exclusions to Reject
Exclusions remove coverage for specific types of claims. Some exclusions are standard and acceptable. Others gut the policy for construction work.
Unacceptable Exclusions for Construction Subs
- Exterior work above a specified height. Reject if the sub works above that height on your project.
- XCU (explosion, collapse, underground). Reject for excavation, foundation, demolition, and blasting subs.
- Residential construction exclusion. Reject if any project component includes residential units.
- Subsidence exclusion. Reject for excavation and grading contractors.
- EIFS/synthetic stucco exclusion. Reject if the sub installs exterior cladding systems.
- Cross-liability/separation of insureds exclusion. Reject always. This exclusion prevents the policy from treating each insured as a separate entity.
- Total pollution exclusion (absolute). Reject for mechanical, plumbing, and any sub handling chemicals or fuels on site.
- Fungi/mold exclusion. Evaluate based on project type. May be acceptable for steel erection but not for interior finish work.
Acceptable Standard Exclusions
These appear on almost every CGL policy and do not need to be negotiated:
- Workers' compensation exclusion (covered by WC policy)
- Auto exclusion (covered by commercial auto)
- Aircraft/watercraft exclusion (not relevant for most construction)
- War/terrorism exclusion
- Nuclear hazard exclusion
Part 5: Annual and Mid-Project Compliance Tasks
CGL verification is not a one-time event. Coverage changes throughout a project.
At contract signing:
- Collect ACORD 25 certificate
- Verify all items in Parts 1-4 above
- Request endorsement copies (not just certificate references)
- Set calendar alerts for policy expiration
30 days before policy expiration:
- Send renewal reminder to sub
- Request updated certificate with new policy dates
- Reverify all limits, endorsements, and exclusions on renewed policy
Mid-project (quarterly on long projects):
- Request current loss runs to check aggregate erosion
- Verify no mid-term policy changes or cancellations
- Confirm carrier remains rated A- VII or better by AM Best
At project completion:
- Verify products-completed operations remains active
- Confirm the sub's CGL will not expire before the statute of repose
- Request written confirmation from the sub's broker on tail coverage
At final payment/retainage release:
- Final certificate verification before releasing retainage
- Confirm all endorsements remain in force
- Archive certificates and endorsements for the statute of repose period
Why Automated Compliance Beats Manual Checklists
This checklist works. But running it manually across 30 to 60 subs per project takes significant time. A 2024 Dodge Construction Network survey found that GCs spend an average of 14 hours per month managing subcontractor insurance compliance manually.
We built SubcontractorAudit to run this entire checklist automatically. The platform extracts data from ACORD 25 forms using AI, compares limits against your project requirements, flags missing endorsements, detects restrictive exclusions, and sends automated reminders 30 days before expiration. One dashboard replaces this entire paper checklist.
Frequently Asked Questions
What is general liability commercial insurance versus a BOP? A BOP (business owner's policy) bundles general liability with commercial property insurance into a single policy at a reduced premium. BOPs work for small, low-risk businesses. Construction subcontractors typically need standalone CGL policies because BOPs carry lower limits ($1M or less) and exclude many construction-specific exposures.
How is commercial general liability different from professional liability? CGL covers bodily injury and property damage from physical operations. Professional liability covers financial loss from errors in professional services (design, engineering, consulting). A design-build sub needs both policies. A trade sub performing physical work only needs CGL.
Can a sub carry CGL from a non-admitted (surplus lines) carrier? Yes, but non-admitted carriers do not participate in state guaranty funds. If the carrier goes insolvent, claims may go unpaid. Require AM Best ratings of A- VII or better and verify the carrier is admitted in your state when possible.
Does general liability commercial insurance cover employee injuries? No. CGL excludes injuries to the insured's own employees. Workers' compensation insurance covers employee injuries. The GC should require both CGL and workers' compensation from every sub.
What is the difference between a general aggregate and a per-project aggregate? The general aggregate is the total amount the policy pays across all projects and claims in a policy period. A per-project aggregate dedicates the full aggregate amount to a single project. On a $2M aggregate policy without per-project endorsement, all the sub's projects share that $2M. With a per-project endorsement, your project gets its own $2M aggregate.
How do I verify that a sub's CGL has not been canceled? The ACORD 25 includes a cancellation notice provision, but it only requires the insurer to "endeavor to" notify certificate holders. This language is not a guarantee. For verified status, contact the carrier directly, request proof of current standing, or use an automated compliance platform that monitors policy status in real time.
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Founder and CEO of SubcontractorAudit. Building AI-powered compliance tools that help general contractors automate insurance tracking, pay application auditing, and lien waiver management.