Guide

Guide

Subcontractor Insurance Requirements: A General Contractor's Guide

Subcontractor Insurance Requirements: A General Contractor's Guide

Author

Author

Author

Patrick Turcotte, COO, Docutrax

Patrick Turcotte, COO, Docutrax

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Read time

Read time

12 mins

12 mins

Updated

Updated

Updated

By Patrick Turcotte, COO, Docutrax. Last reviewed: 14 July 2026.

Subcontractor insurance requirements are the coverages, limits, and policy endorsements a general contractor requires each subcontractor to carry before it starts work. Their purpose is to move the financial consequences of a subcontractor's work off the general contractor's own insurance and onto the subcontractor's.

This guide covers what to require, how limits are typically set, which endorsements make the requirements actually reach the general contractor, and how far verification needs to go. It is written for general contractors, construction managers, owners, and the risk and compliance teams that oversee them.

What insurance should a general contractor require from a subcontractor?

Most commercial construction requires the same core coverages, at limits that scale with the trade and the project.

Commercial general liability is the foundation. It responds to third-party bodily injury and property damage arising from the subcontractor's operations. Most contracts reference the standard ISO CG 00 01 policy form. It does not cover the subcontractor's own employees, which is workers compensation, and it does not cover faulty workmanship as a financial loss, which is a different matter.

Workers compensation and employers liability. Required by statute in every state except Texas for businesses with employees, subject to small-employer thresholds in some states that generally do not apply to construction, where coverage is typically required from the first employee. It covers medical costs and lost wages for injured workers. If a subcontractor lacks it and one of their workers is injured on the site, the general contractor can end up liable under state law, which is why every general contractor confirms it before granting site access.

Automobile liability, covering owned, hired, and non-owned vehicles used in the work.

Umbrella or excess liability, sitting above the primary limits on projects where a single loss could exceed the primary aggregate.

Trade-specific coverage where the scope calls for it: professional liability for design-build or any subcontractor who stamps drawings or provides design input, and pollution liability for abatement, demolition, excavation, and hazardous materials work.

What limits should a general contractor require?

Limits scale with the trade's risk, the project value, and any owner or lender mandates. The following are common commercial construction baselines, not rules, and any specific contract should be set against its own exposure.

The general liability baseline most often seen in commercial subcontracts is 1 million dollars per occurrence and 2 million dollars general aggregate. It is the floor for the majority of commercial work, and showing up with less is usually a non-starter. ( Construction Coverage.) [SOURCE: replace with IRMI or an AGC benchmark if available; do not cite LegalClarity anywhere on the site]

Limits by trade risk, as a common starting point:

Trade risk

Example trades

Typical GL requirement

Lower risk

Landscaping, low-voltage, flooring, painting

1M per occurrence / 2M aggregate

Moderate risk

Roofing, electrical, HVAC, excavation, concrete

2M per occurrence / 4M aggregate, plus umbrella

Higher risk

Structural steel, crane, demolition

5M to 10M, often higher near occupied buildings

 

Umbrella limits commonly run to 5 million dollars on projects from 1 to 5 million dollars, 10 million dollars on projects from 5 to 25 million dollars, and higher on larger work and high-hazard trades. The umbrella should follow form over the underlying general liability, automobile, and employers liability, so it mirrors their terms rather than introducing its own exclusions. (Policyhold.)

Two limit details are quietly important and easy to miss.

Per-project aggregate. A standard general aggregate is a shared pool that drains as the subcontractor pays claims on all its jobs. A claim on an unrelated project can exhaust the aggregate that was supposed to protect yours. A per-project aggregate endorsement dedicates a fresh aggregate to your project. On any significant job it is worth requiring. (Construction Coverage.)

Occurrence, not claims-made. General liability should be written on an occurrence form, which responds to an incident that happened during the policy period whenever the claim is made. A claims-made form responds when the claim is first made during the policy period or an extended reporting period, and only for incidents that happened after the policy's retroactive date. Because construction claims frequently surface years after completion, a claims-made policy that lapses after the job ends can leave nothing to claim against. Well-drafted subcontracts prohibit claims-made general liability without written consent.

A subcontractor's experience modification rate, its EMR, is also worth reading. It indexes their workers compensation claims history against expected losses for operations of similar class and size, and an EMR well above 1.0 is a signal about how the subcontractor manages safety.

Why do endorsements matter more than the limits?

Because a limit the general contractor cannot reach does the general contractor no good.

A subcontractor can carry a 5 million dollar policy, and if the general contractor is not an additional insured on it, the policy pays the subcontractor's defence and indemnity and nothing flows to the general contractor. The claim is against the subcontractor, the coverage is the subcontractor's, and the general contractor's own program absorbs whatever the subcontractor cannot or will not pay.

The endorsements are what convert the subcontractor's limits into coverage the general contractor can actually claim on. There are four, and each is a written grant on the subcontractor's policy, whether by scheduled endorsement, blanket endorsement, or built-in policy provision, that a certificate can reference but not prove.

Additional insured, ongoing operations. The common CG 20 10 grants the general contractor additional insured status for the subcontractor's ongoing operations. ISO revised it in 1993 to rule out completed operations. (IRMI.)

Additional insured, completed operations. CG 20 37 restores additional insured status for completed operations, the exposure that surfaces after the subcontractor has finished and left. Requiring only CG 20 10 leaves a gap that opens the day the subcontractor walks off, and a defect discovered months later is uncovered. Both endorsements are needed.

Waiver of subrogation. CG 24 04 stops the subcontractor's insurer from recovering its payout from the general contractor after it pays a claim. It does not add additional insured status and it does not create primary and noncontributory coverage. And only the insurer waives: the subcontractor itself can still pursue the general contractor directly. (IRMI.) On workers compensation, note that several states restrict or prohibit a waiver of subrogation, so a workers comp waiver is not universally available. (Policyhold.)

Primary and noncontributory. CG 20 01 puts the subcontractor's policy first. Under standard ISO wording the priority already runs the right way: the subcontractor's policy is primary for an additional insured, and the general contractor's own policy sits excess over coverage available to it as an additional insured. What the endorsement adds is certainty. Not every subcontractor's carrier writes on ISO forms, and many proprietary additional insured endorsements make the coverage excess unless a written contract requires primary. CG 20 01 forces the intended priority regardless of whose forms are in play, and it bars the subcontractor's carrier from seeking contribution from the general contractor's policy. (ISO CG 00 01, Other Insurance condition; IRMI.)One caution on form numbers. Many subcontractor programs grant these protections through blanket endorsements rather than scheduled ones: CG 20 33 for automatic ongoing operations status when required by written contract, CG 20 39 for the completed operations equivalent, CG 20 38 and CG 20 40 where upstream parties without a direct contract need status, and CG 24 53 as the blanket waiver of subrogation. A subcontractor presenting blanket forms can be fully compliant with a subcontract that names CG 20 10 and CG 20 37 or their equivalents. The verification question is not whether the form number matches. It is whether the grant reaches the right parties: CG 20 33 requires a direct written contract with the named insured, so it does not reach an owner the subcontractor never contracted with unless the other-parties forms are present.

The insurance endorsements guide covers all four in depth. The point for a requirements schedule is that all four must be named in the subcontract, ideally by ISO form number or equivalent, and then confirmed on the policy rather than trusted from the certificate.

When must the coverage be in place, and for how long?

Coverage has to exist before mobilization, not at first invoice, and it has to persist past completion.

Before mobilization. The certificate and, on higher-risk work, the endorsements should be confirmed before the subcontractor is on site. A subcontractor working for three weeks before its certificate arrives is three weeks of uninsured exposure the general contractor cannot recover.

Through the completed-operations tail. Most claims that reach a general contractor surface after the work is done. Completed operations coverage and the CG 20 37 additional insured status should be maintained for a defined tail after completion, and that tail should track the statute of repose in the state where the project sits, not the end of the project. Coverage that ends at practical completion does not answer a defect claim that arrives two years later.

At every renewal in between. A certificate is a snapshot, and coverage can lapse or change mid-project. Requirements are enforced through renewal tracking, not a single collection at intake.

Why require additional insured status if the subcontract already indemnifies you?

Because the indemnity clause and the additional insured endorsement cover different failures, and neither substitutes for the other.

The indemnity clause carries the legal obligation. Additional insured status gives the general contractor direct access to the subcontractor's policy as an insured, and that access solves two problems the indemnity clause alone does not.

Defence costs. A CGL policy provides uncapped defence costs for an additional insured that do not erode the limits. Where the general contractor relies only on the indemnity clause and its contractual liability coverage, defence is generally paid within the limits, unless the narrow supplementary payments conditions are met, which they frequently are not, so defence and indemnity together are capped and the available indemnity shrinks as the case runs. (IRMI.)

The action-over problem. For the subcontractor's insurer to owe the general contractor a defence under the indemnity clause, the subcontractor generally has to be named in the same suit. In the commonest construction scenario it is not: the subcontractor's own injured employee sues the general contractor and cannot sue their employer, because workers compensation is the exclusive remedy. The subcontractor is never named in the suit. The general contractor can still enforce the clause by bringing the subcontractor in as a third-party defendant, and in New York, Workers' Compensation Law section 11 expressly permits that claim where a written indemnification contract exists. But that route means litigating against the subcontractor, proving the indemnity, and funding a defence in the meantime. Additional insured status depends on none of it: the general contractor tenders directly to the subcontractor's carrier and the defence obligation is immediate.That is why it is required alongside the clause rather than instead of it.

The contractual risk transfer guide covers this interaction, including the case where a state statute voids the indemnity clause and takes the insurance behind it. The short version: require both.

Does New York change the requirements?

The requirements list does not change. The stakes do, and by a wide margin.

New York Labor Law section 240, the Scaffold Law, enacted in 1885, imposes absolute liability on owners and general contractors when a construction worker is injured by a gravity-related risk, such as a fall from height or a falling object. The duty is non-delegable, comparative negligence by the worker is not a defence, the only recognized escape is the narrow sole proximate cause defence, and owners and general contractors can be sued even where the injured worker was employed by a subcontractor. As of May 2026, no amendment to section 240 has passed. (NY Senate, Labor Law section 240; JTNY, May 2026.)

The practical effect is that a gravity-related injury to a subcontractor's worker becomes a claim against the general contractor almost by default, and the only path to move that loss back downstream is the subcontractor's insurance.

Section 241(6) is related but different: it imposes a non-delegable duty to comply with specific Industrial Code regulations, it is not absolute, and comparative negligence applies. (JTNY, May 2026.) Serious injuries are often pleaded under both sections at once.

The frequency is not a rounding difference. Per Chubb, New York averages one bodily injury general liability claim for every 2.74 million dollars in construction payroll, against one per 37 million dollars across all other states: more than twelve times the claim frequency. (Chubb and Aon.) A gap in a subcontractor's additional insured coverage on a project in most states may never surface. The same gap in New York surfaces at more than twelve times the rate, into a liability structure with no comparative-negligence defence.

Can a subcontractor's policy exclude New York Labor Law losses?

Yes, and this is the point at which certificate and endorsement checks stop being enough.

Downstream subcontractors' policies can carry exclusions for New York Labor Law losses. (Chubb and Aon.) The subcontractor's certificate can be clean, every endorsement can be present and correctly written for the general contractor, and the policy underneath can still carry an exclusion that removes coverage for exactly the exposure that drives New York construction litigation.

A certificate cannot show that. An endorsement summary cannot show that. Only reading the policy can. For New York construction, and for high-exposure work generally, the requirements process has to include a reading of the policy for exclusions before the subcontractor mobilizes. Finding a Labor Law exclusion after a claim is not a compliance finding, it is a loss.

What should a general contractor verify before a subcontractor starts work?

The requirements are set in the subcontract. Verification is where they are confirmed against reality, and it starts at the certificate without ending there.

Requirement

What the certificate confirms

What has to be verified

Commercial general liability

Coverage type, limits, dates, occurrence form

No exclusion applies to the subcontractor's scope; the policy has not been narrowed by coverage-removing endorsements

Per-project aggregate

Rarely shown

A per-project aggregate endorsement is on the policy where the subcontract requires it

Additional insured, ongoing operations

A reference, often "CG 20 10"

CG 20 10 or a blanket equivalent is on the policy, in the edition the subcontract specifies, correct legal entity

Additional insured, completed operations

A reference, sometimes omitted

CG 20 37 or a blanket equivalent is present, since ongoing operations status does not cover post-completion claims

Waiver of subrogation

A checkbox or note

The waiver is endorsed in favour of the general contractor and owner

Primary and noncontributory

A checkbox or note

The endorsement language is on the policy, not merely asserted

Workers compensation

Coverage and limits

Coverage is active and names the correct entity; the EMR is worth reviewing

Umbrella or excess

Limits

The umbrella follows form over the primary that carries the additional insured status, and extends that status into the excess layer, which does not happen automatically

New York projects

Nothing specific

The policy carries no exclusion for New York Labor Law losses

Timing

Policy dates

In force before mobilization, maintained through the completed-operations tail

 

Every line in the right-hand column is a policy-level or endorsement-level fact the certificate does not establish. Edition matters more than it looks: ISO's additional insured endorsements have narrowed with each major revision, with the 2013 and 2019 editions limiting coverage to what the written contract requires and capping limits at the lesser of the contract-required limits or the policy limits. The pass condition is the edition and breadth the subcontract calls for, not simply the newest form. The depth of that verification should match the exposure. For a low-risk trade on a modest project, confirming the certificate and the key endorsements is proportionate. For high-hazard trades, high project values, and New York work, the policy itself has to be read.

Docutrax runs this verification on construction accounts. Certificates, endorsements, and policies are reviewed by licensed P&C professionals, and construction accounts are handled by CRIS-certified Account Managers, on a base of more than 300,000 complete policy reviews since 2017. For high-exposure work the review is a Comprehensive Policy Review that reads the policy for exclusions, endorsement editions, and entity names. Where a subcontractor's coverage falls short of the contract, the correction is coordinated with the broker or agent and the facts go back to the client. Docutrax does not decide whether a non-compliant subcontractor mobilizes. The client decides, with the coverage picture in

FAQs

Quick answers

What are the standard subcontractor insurance requirements?

Commercial general liability, workers compensation, and automobile liability at minimum, with umbrella or excess on larger work and trade-specific coverage where the scope requires it. Plus the four endorsements that carry risk transfer: additional insured for ongoing and completed operations, waiver of subrogation, and primary and noncontributory.

What GL limits should a general contractor require from a subcontractor?

The common commercial baseline is 1 million dollars per occurrence and 2 million dollars aggregate. Moderate-risk trades often require 2 million by 4 million plus an umbrella, and high-hazard trades such as steel, crane, and demolition frequently require 5 to 10 million. Match the requirement to the worst credible loss, not the average job.

Which endorsements should be on every subcontractor's CGL?

Four: CG 20 10 for additional insured ongoing operations, CG 20 37 for completed operations, CG 24 04 for waiver of subrogation, and CG 20 01 for primary and noncontributory, or their blanket equivalents such as CG 20 33, CG 20 39, and CG 24 53. Requiring any subset leaves a gap the certificate does not show.

Do New York projects require different insurance?

The endorsement stack is the same. What changes is the exposure. Section 240 imposes absolute liability on owners and general contractors for gravity-related injuries, New York sees bodily injury claims at more than twelve times the rate of all other states combined, and a subcontractor's policy can carry an exclusion for Labor Law losses that only a policy review will find.

Does the indemnity clause replace additional insured status?

No. The indemnity clause carries the legal obligation. Additional insured status keeps defence costs from eroding the limit and solves the action-over problem, where a subcontractor's injured employee sues the general contractor and the subcontractor is never named. Enforcing the clause means litigation; tendering as an additional insured means an immediate defence. Require both.

How long should a subcontractor maintain coverage?

Coverage must be in place before mobilization and maintained through the completed-operations tail, which should track the statute of repose in the project's state rather than ending at completion. Most claims reaching a general contractor surface after the work is done.

Related Articles

Contractual Risk Transfer: Indemnity, Insurance, and Where the Chain Breaks

How contractual risk transfer works: indemnify, defend, and hold harmless, the insurance requirements schedule, and the endorsements that fund the promise.

Insurance Endorsements: What They Are and Which Ones Carry Risk Transfer

Insurance endorsements, not the certificate, decide whether coverage responds. What CG 20 10, CG 20 37, CG 24 04, and CG 20 01 do, and where they fail.

Certificate of Insurance: How to Read One and Verify It

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Managed third-party insurance compliance for the organizations that carry the exposure.

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Managed third-party insurance compliance for the organizations that carry the exposure.

Risk Toolbox, Inc.

4 Century Drive Suite 240 Parsippany, NJ 07054

Managed third-party insurance compliance for the organizations that carry the exposure.

Risk Toolbox, Inc.

4 Century Drive Suite 240 Parsippany, NJ 07054