COI Compliance Requirements by State: What GCs and Property Managers Actually Need to Check

A certificate of insurance that satisfies a subcontract in Texas will get a sub kicked off a job site in New York. COI compliance is not a single national standard — it is a patchwork of state insurance regulations, statutory workers' compensation thresholds, lien law requirements, and contract custom that shifts every time you cross a state line. This post maps the material differences so you know exactly what to demand before work begins.

By Nick Streicher, Founder, StrikeDocs. Published 2026-04-23.

Why COI requirements vary by state (and why that matters on day one)

The certificate of insurance form most people use — the ACORD 25 — is a standardized document, but the insurance behind it is anything but standardized. States regulate minimum coverage amounts, mandatory policy types, cancellation notice periods, and the legal weight of endorsements differently. A COI is only a snapshot of a policy; the policy itself must comply with the state where the work is performed, not the state where the insurer is domiciled or where the sub is headquartered.

For a general contractor, this creates a real administrative problem. You may be managing subs licensed in five different states, working on a project in a sixth. Each sub's COI needs to reflect coverages that satisfy the project state's requirements, the contract's requirements, and your own upstream obligations to the owner or lender. Getting any one of those wrong exposes you to uninsured loss, contract breach, or worse — a workers' compensation audit that claws back your classification credits because a sub's WC was void in the project state.

The stakes are highest at project inception. Most subcontract agreements make the sub's COI a condition precedent to starting work. That means the compliance problem is a day-zero problem, not something you sort out mid-project.

The federal baseline: what every COI must have regardless of state

Before getting into state specifics, it helps to establish what the floor looks like across all U.S. commercial construction projects.

Commercial General Liability (GL): Required on virtually every commercial project. The ACORD 25 captures per-occurrence and aggregate limits. Standard contract language from the American Institute of Architects and ConsensusDocs calls for $1,000,000 per occurrence / $2,000,000 aggregate as a minimum. Some owners push to $2M/$4M on larger projects.

Workers' Compensation: Required in every state except Texas (discussed below). The statutory limit is state-specific; the ACORD 25 lists it as "Statutory." The employers' liability limits beneath it — often called the "Part B" limits — are negotiable and typically set at $500,000/$500,000/$500,000 or $1,000,000/$1,000,000/$1,000,000 on commercial jobs.

Commercial Auto: Required when any vehicle is used in connection with the work. The standard minimum is $1,000,000 combined single limit.

Umbrella/Excess: Increasingly required on projects above a certain contract value, typically $5M+. Umbrella limits of $5,000,000 to $25,000,000 are common depending on project size and owner risk appetite.

Endorsements: The ACORD 25 has a Description of Operations box where endorsements are listed. Additional Insured, Waiver of Subrogation, and Primary & Noncontributory language are the three most commonly required. Whether those endorsements actually appear — and whether they are on the correct ISO form — is where most COI review failures happen.

For a deeper look at how these fields map to the ACORD 25 form itself, see our post on how to read an ACORD 25.

New York: the strictest environment in the country

New York is in a category of its own. The state imposes requirements that exist nowhere else, and the consequences of non-compliance are severe because New York's Labor Law sections 240 and 241 create near-strict liability for gravity-related injuries on construction sites. Owners and GCs absorb that liability, which means the insurance chain has to be airtight.

Workers' Compensation — C-105.2 and DB-120.1: New York requires a separate WC certificate on the state's own form (C-105.2 for WC, DB-120.1 for disability benefits) in addition to whatever appears on the ACORD 25. Many GCs from out of state do not know this and accept an ACORD 25 with WC listed — only to discover during a Department of Labor audit that the separate state form was never obtained. The New York Workers' Compensation Board enforces this aggressively.

Disability Benefits: New York is one of a handful of states that require statutory disability benefits coverage (short-term disability) separate from WC. Subs must carry it; the certificate must show it.

Additional Insured forms: New York courts have repeatedly scrutinized whether the Additional Insured endorsement on a sub's policy actually triggers coverage for the GC and owner. The ISO CG 20 10 04 13 (ongoing operations) and CG 20 37 04 13 (completed operations) forms are the current standard. Older forms — especially anything pre-2004 — may not satisfy New York contract requirements or may be interpreted differently by courts.

Cancellation notice: Many New York contracts require 30-day notice of cancellation, which must be confirmed by endorsement on the policy itself, not just noted in the Description of Operations box. The ACORD 25 previously printed "30 days" in the cancellation section as a default; ACORD revised the form to remove that language precisely because it was not backed by policy endorsement. If your contract requires 30-day notice, verify the endorsement exists.

California: contractor licensing ties directly to COI

California's Contractors State License Board (CSLB) requires licensed contractors to maintain certain insurance as a condition of licensure. That creates a linkage that GCs can use: if a sub's COI shows lapsed or insufficient coverage, their CSLB license may itself be in jeopardy, which affects their ability to legally perform work on the project.

Workers' Compensation: California has some of the highest WC premiums in the country and a robust enforcement apparatus. Uninsured employers face stop-work orders, fines, and criminal penalties. The CSLB requires contractors with employees to carry WC; sole proprietors can file a Certificate of Exemption, but that exemption does not extend to any employees they hire, and GCs should not accept an exemption certificate for a sub who shows up with a crew.

Wrap-up insurance programs (OCIPs/CCIPs): California is one of the largest markets for wrap-up programs on public and large private projects. If the project is enrolled in a wrap-up, the sub's COI requirements change — they typically exclude GL (covered by the wrap) but must still show WC, auto, and any professional or pollution coverage not included in the wrap. Failing to coordinate this correctly results in double coverage on some lines and gaps on others.

Additional Insured — completed operations: California's statutes on indemnity (Civil Code § 2782) restrict certain indemnity agreements in construction contracts, which affects how Additional Insured coverage for completed operations is drafted. Blanket contractual indemnity provisions that shift 100% of the indemnitee's own negligence to the sub are void in California. This does not eliminate the AI requirement, but it affects what the AI endorsement can actually do.

Florida: statutory WC thresholds and the exemption trap

Florida has industry-specific WC thresholds that catch out-of-state GCs regularly.

Construction industry threshold: In Florida, any business in the construction industry with one or more employees — including the owner — must carry WC. This is more aggressive than most states, which trigger the requirement at three or four employees. The Florida Division of Workers' Compensation issues stop-work orders to uninsured construction employers; those orders apply to the entire business, not just the project.

Officer exemptions: Florida allows corporate officers in the construction industry to claim a WC exemption, but the exemption is limited to three officers per corporation. Subs sometimes present COIs that show WC as "not applicable" or present an exemption certificate — if the sub has four or more officers on site, the fourth is not covered under the exemption and triggers the coverage requirement. Verify headcount.

Roofing contractors: Florida has additional licensing and insurance requirements specific to roofing contractors, including minimum GL limits set by statute. The $300,000 per-occurrence statutory minimum for roofing contractors is lower than what most GC contracts require, so contract minimums typically govern — but be aware that a roofing sub's insurer may have underwritten the policy to the statutory floor, not to your contract's higher requirement.

Texas: the opt-out state that confuses everyone

Texas is the only state where private employers can legally opt out of the workers' compensation system. A sub in Texas can lawfully carry no WC coverage at all. This does not mean you should let them on your job site without it.

Non-subscriber liability: Texas employers who opt out of WC (called "non-subscribers") lose the exclusive-remedy protection that WC provides. That means an injured employee can sue the employer directly in tort, and can sue the GC for negligent hiring or supervision. From a GC's risk management standpoint, a non-subscriber sub is a larger liability exposure than an uninsured sub in another state, because the litigation path is cleaner.

Contract requirements override the opt-out: Most commercial GC subcontracts in Texas contractually require WC coverage regardless of the state opt-out. Verify that the sub's COI shows WC coverage, not just an employer's liability policy. Those are not the same thing in Texas.

Additional Insured endorsements: Texas uses its own standard policy forms for some lines. Verify that AI endorsements are on ISO forms (or equivalent Texas Bureau of Insurance-approved forms) that match what your contract requires. The CG 20 10 / CG 20 37 split is the same as everywhere else, but the underlying policy language can differ.

Other states worth flagging

New Jersey: NJ follows a similar Workers' Compensation structure to New York and requires separate disability benefits coverage. The state also has a relatively active Department of Banking and Insurance that regulates cancellation notice requirements — 30-day notice endorsements should be verified, not assumed from the ACORD form.

Washington: Washington has a state-fund WC system (Labor & Industries) for most industries. Private WC insurance is not available for most construction work in Washington — the employer pays into the state fund directly. A COI showing a private insurer on the WC line for Washington-based work is often incorrect. The ACORD 25 for Washington work should show "WA L&I" or the employer's L&I account number, not a private carrier.

Oregon: Oregon also has a state WC system but allows private insurers. Oregon requires a 10-day cancellation notice for non-payment and a 30-day notice for other reasons, and those must be reflected in the policy, not just noted on the certificate.

Georgia: Georgia has relatively permissive WC thresholds (three or more employees triggers the requirement in most industries) but enforces them through the State Board of Workers' Compensation, which has reciprocal agreements with neighboring states. Out-of-state subs working in Georgia on short projects may be covered under their home-state policy for a limited period — verify the policy's other-states endorsement.

Endorsements that travel with the state requirement

Regardless of state, three endorsements drive the majority of COI compliance failures on commercial construction projects.

Additional Insured (CG 20 10 / CG 20 37): The split between ongoing operations (CG 20 10) and completed operations (CG 20 37) matters. Many subs carry one but not the other. Completed operations coverage extends after the project is done and is where latent defect claims originate. If your contract requires AI for completed operations and the COI only shows CG 20 10, you have a gap.

Waiver of Subrogation: This endorsement prevents the sub's insurer from suing the GC or owner after paying a claim. Without it, a sub's GL or WC carrier can subrogate against you for a loss that you arguably caused or contributed to. It must be on the policy itself — listing it in the Description of Operations without a policy endorsement is not enforceable.

Primary & Noncontributory: This endorsement makes the sub's policy respond first before your own GL, and prevents the sub's insurer from calling on your policy to contribute. Without it, you may find your own GL being eroded by claims that should be sitting on the sub's policy.

For a detailed walkthrough of what each of these endorsements does to actual coverage, see our post on what a COI covers.

What we learned running 59 real COIs through StrikeDocs

We processed 59 COIs through StrikeDocs — documents spanning 23 states and Washington D.C., drawn from real subcontractor files submitted on active construction projects. Here is what the data showed.

Only 33.9% of policies included an Additional Insured endorsement. Given that AI is required on virtually every commercial subcontract, this means roughly two out of three policies in a typical sub file are non-compliant on that point alone before you look at anything else.
Waiver of Subrogation appeared on just 21.3% of policies, and Primary & Noncontributory on only 15.5%. These two endorsements travel together in most subcontract templates — if one is missing, the other usually is too. The data confirmed that pattern: documents missing one almost always missed both.
100% of GL policies in the set had a per-occurrence limit below $1,000,000 — the median each-occurrence figure was $10,000, with a range of $2,500 to $40,000. This finding reflects a data artifact: the policies extracted were likely reporting sub-limits (such as damage to rented premises or medical payments) rather than the primary per-occurrence limit, which suggests the extraction field mapping needs a secondary validation pass for GL limit type. It is also a good illustration of why automated COI review needs human verification on limit fields — misread sub-limits flagged as primary limits are a real failure mode in both manual and automated review.
New York represented 27% of all documents in the set (16 of 59), followed by California at 17% (10 of 59) and Florida at 8% (5 of 59). The geographic concentration in high-scrutiny states tracks with where commercial construction volume and subcontract compliance pressure are highest — and reinforces why NY and CA deserve the most detailed treatment in any state-by-state compliance framework.
The most common endorsement form by name was CG 20 10 04 13, appearing seven times across the corpus. The 2013 edition of this form is the current standard; if you see an older edition date (04 93, 07 04), verify whether your contract specifies a minimum form edition.

These numbers come from real subcontractor COIs, not hypothetical scenarios. The pattern they reveal is consistent with what any experienced GC risk manager already knows anecdotally: endorsement compliance is the primary failure mode, not policy type or basic limit adequacy.

How to build a compliant COI checklist for multi-state operations

If your company operates across multiple states, a single generic COI checklist will create compliance gaps. Here is a framework for building one that holds up.

Step 1: Establish the project state as the governing jurisdiction. Coverage must comply with the laws of the state where the work is performed. The sub's home-state policy must have an other-states endorsement or must be a multi-state policy. Verify this on the declarations page, not the ACORD 25.

Step 2: Pull the state-specific statutory requirements before you finalize the subcontract. For WC, check whether the project state has a state fund (Washington, Ohio, Wyoming, North Dakota), an opt-out provision (Texas), or specific exemption rules (Florida). Do not rely on your standard subcontract template to capture these — it probably does not.

Step 3: Confirm that AI, WOS, and P&NC endorsements are backed by policy endorsements, not just noted on the certificate. Request the actual endorsement pages if you have leverage in the relationship. At minimum, verify that the endorsement form numbers are listed in the Description of Operations box, not just the words "Additional Insured" or "Waiver of Subrogation."

Step 4: Set a renewal tracking calendar. A COI is a point-in-time snapshot. If a sub's policy renews on July 1 and your project runs through December, you need a new COI in July. Automated tracking is the only reliable way to do this at scale — manual calendar reminders fail as subcontractor lists grow.

Step 5: Document your review. When a COI is accepted as compliant, record who reviewed it, when, and what criteria were applied. If a claim arises and coverage is disputed, your review documentation is evidence that you exercised reasonable care in vendor qualification.

For more on the foundational structure of the ACORD 25 certificate itself, including how the form fields map to policy terms, see our post on ACORD 25 explained.

The following is an example of a structured compliance-check output from StrikeDocs for a single policy extracted from a COI:

ISSUE: Additional Insured endorsement not present on GL policy
FIELD: Description of Operations / Endorsements
SEVERITY: HIGH

ISSUE: Waiver of Subrogation not confirmed by endorsement form number
FIELD: Description of Operations / Endorsements
SEVERITY: HIGH

ISSUE: GL each-occurrence limit below contract minimum of $1,000,000
FIELD: Commercial General Liability — Each Occurrence
SEVERITY: CRITICAL

ISSUE: WC policy does not show project state (NY) on declarations
FIELD: Workers Compensation — Policy State
SEVERITY: HIGH

This output format is what StrikeDocs produces after parsing the ACORD 25 fields and comparing them against the compliance rules loaded for the project. A human reviewer then acts on each flagged issue before approving the sub to mobilize.