The phrase "if any workers compensation policy" appears on ACORD certificate forms and in contract language across the construction industry. It signals a conditional check: does this subcontractor carry WC coverage, and if so, does it meet your requirements? For GCs managing compliance across dozens of subs, that conditional check needs to become a systematic verification process.

In 2024, 5.8% of construction WC policies lapsed at least once during the policy year, according to NCCI data. Another 3.2% of certificates presented to GCs showed policies that had already been cancelled. Without a structured checklist, these gaps slip through.

The ACORD Certificate WC Compliance Checklist

Start with the ACORD 25 certificate. Every field in the WC section tells you something about the sub's compliance status.

Checkpoint 1: Confirm WC Coverage Exists

The WC section of the ACORD form has a checkbox labeled "Workers Compensation and Employers' Liability." If this box is not checked and no carrier information appears, the sub does not carry WC insurance.

In Texas, WC is optional for private employers. A Texas-based sub may legitimately lack WC coverage. However, most GC contracts and project owners require WC regardless of state law. If your contract requires WC and the sub checks "N/A," reject the certificate.

Checkpoint 2: Verify the Carrier

The insurer column lists the WC carrier name and NAIC number. Verify two things:

Carrier licensing. The carrier must be licensed in the state where work occurs. A carrier licensed in Florida may not be authorized to write WC in Georgia. Check the state insurance department's website for carrier licensing status.

Financial strength. Look up the carrier's A.M. Best rating. Ratings of A- (Excellent) or higher indicate strong claims-paying ability. A carrier rated below B+ may struggle to pay large claims. About 0.4% of WC carriers were placed in receivership or liquidation between 2019 and 2024.

A.M. Best Rating	Meaning	GC Action
A++ to A+	Superior	Accept
A to A-	Excellent	Accept
B++ to B+	Good	Accept with monitoring
B to B-	Fair	Request additional documentation
Below B-	Marginal/Weak	Reject, require new carrier
Not rated	Unknown financial strength	Investigate before accepting

Checkpoint 3: Validate Policy Dates

The effective and expiration dates on the certificate define when coverage applies. Your checklist should flag three situations:

Policy already expired. The certificate shows an expiration date that has passed. This happens when subs submit old certificates. Reject immediately and request a current certificate.

Policy expires before project completion. A 16-month project starting in January 2026 needs WC coverage through April 2027. If the policy expires in December 2026, set an alert for 30 days before expiration to request a renewal certificate.

Policy issued after work started. If the effective date is after the sub's first day on site, a coverage gap exists for those initial days. Any injury during that gap falls to you as the statutory employer.

Checkpoint 4: Confirm Statutory Coverage

Part One of the WC section should show "statutory" or have the statutory checkbox marked. This means the policy pays benefits as required by state law.

If the certificate shows specific dollar amounts instead of "statutory" for Part One, the document may be altered or fraudulent. Statutory WC coverage has no dollar limit because state laws dictate benefit levels. Contact the carrier to verify.

Checkpoint 5: Check Employers Liability Limits

Part Two shows three limits. Compare them against your contract requirements.

Most standard GC contracts require:

Each accident: $1,000,000
Disease policy limit: $1,000,000
Disease each employee: $1,000,000

Smaller projects may accept the base limits of $100,000/$500,000/$100,000. Federal projects and large commercial work typically require $1,000,000 across all three.

If the sub's limits fall below your contract requirements, they need to increase coverage before starting work. Adding an umbrella or excess policy is one option.

Checkpoint 6: Verify State Coverage

The WC section lists covered states. If your project is in Georgia but the sub's policy only shows coverage for Alabama, the policy may not respond to a Georgia injury.

Check three items:

Item 3A states include your project state
Item 3C (Other States) provides backup for unlisted states
Monopolistic states (OH, ND, WA, WY) require separate state fund policies

For multi-state projects, create a state coverage matrix showing every project state and confirming each sub has WC coverage in that state.

Project State	Sub A Coverage	Sub B Coverage	Sub C Coverage
Georgia	Listed in 3A	Listed in 3A	Listed in 3C
Florida	Listed in 3A	Listed in 3C	Listed in 3A
Ohio	Separate BWC policy	Not covered (gap!)	Separate BWC policy
South Carolina	Listed in 3C	Listed in 3A	Listed in 3C

Checkpoint 7: Review Endorsements

Three endorsements matter on a WC policy:

Waiver of subrogation. Prevents the sub's carrier from suing you. Required by most GC contracts. The ACORD certificate notes this endorsement in the Description of Operations box or with a checkbox.

Additional insured. WC policies do not carry additional insured endorsements. However, the sub's companion general liability policy should name you as additional insured. Verify this on the same ACORD certificate.

Officer/partner exclusion. If the sub excluded owners from WC coverage, the endorsement page lists excluded names. Request this page and cross-reference against on-site personnel.

Checkpoint 8: Confirm No Outstanding Cancellation

A certificate can show active dates while the policy has been cancelled. Carriers issue certificates at policy inception. Cancellations happen later.

Verify active status through one of these methods:

Call the carrier's certificate verification line
Use the carrier's online verification portal
Check the state's employer coverage database (available in about 35 states)
Use an automated compliance platform that monitors carrier databases

Checkpoint 9: Cross-Reference Class Codes

Request the policy declarations page. Compare each class code to the sub's scope of work on your project.

If a plumbing sub (code 5183) will also perform HVAC work on your project, they need a separate class code for HVAC (code 5537). A single class code covering only plumbing leaves HVAC work unclassified and potentially uncovered.

Checkpoint 10: Document Everything

Store every certificate, declarations page, endorsement, and verification result in a central compliance file. Your WC carrier will request these documents at your annual audit.

Retention requirements:

Active project files: keep certificates current throughout the project
Completed project files: retain for 5 years minimum (matches most states' statute of limitations for WC claims)
Annual audit documentation: retain for 7 years

Monthly Compliance Review Calendar

Set up a recurring monthly review to catch gaps before they become claims.

Week	Task	Focus
Week 1	Expiration scan	Flag all certificates expiring within 60 days
Week 2	New sub verification	Process certificates for newly contracted subs
Week 3	Cancellation check	Verify active status on 25% of certificates
Week 4	Documentation audit	Confirm all required endorsements are on file

SubcontractorAudit automates this entire calendar. Expiration alerts fire automatically. Carrier verification runs daily. Missing endorsements generate action items for your compliance team.

See how automated compliance works

Frequently Asked Questions

What does "if any" mean on an ACORD workers compensation certificate? The phrase "if any" on an ACORD form indicates a conditional field. It means the information applies only if the coverage exists. For WC, if the sub carries a WC policy, the section should be completed with carrier name, policy number, dates, and limits. If no WC exists (rare in construction), the section remains blank or shows N/A.

How do I verify a workers compensation policy is still active? Call the carrier's certificate verification department using the policy number from the ACORD certificate. Many carriers offer online portals for real-time verification. About 35 states maintain employer coverage databases where you can look up a sub's WC status by name or tax ID number. Automated platforms like SubcontractorAudit check carrier databases daily.

What happens if a sub's WC policy gets cancelled mid-project? The carrier sends a cancellation notice to the certificate holder (you). Notice periods range from 10 to 30 days depending on the state and reason for cancellation. During the notice period, contact the sub and require proof of replacement coverage before the cancellation effective date. If the sub cannot obtain replacement coverage, stop their work until they do.

Can I accept a WC certificate from a state fund instead of a private carrier? Yes. State fund WC coverage is valid in every state that operates a state fund. In monopolistic states (OH, ND, WA, WY), the state fund is the only option. State fund certificates may use non-standard formats, but the coverage is legitimate. Verify active status through the state fund's employer lookup portal.

What class codes should I verify on a sub's WC policy? Verify that the class codes on the sub's policy declarations page match the trades they will perform on your project. Common construction codes include 5403 (carpentry), 5190 (electrical), 5183 (plumbing), 5213 (concrete), 5551 (roofing), and 5606 (GC supervision). If the sub performs work outside their listed class codes, their carrier may deny claims for that work.

How long should I keep workers compensation certificates on file? Keep certificates from active projects current throughout the project duration. After project completion, retain certificates for at least 5 years. This matches the statute of limitations for WC claims in most states and satisfies your own WC carrier's audit requirements. Some states allow claims to be filed up to 7 years after injury, so longer retention provides added protection.