1. Find out which of three things happened
An ACORD 25 is a snapshot. The form states that it is issued as a matter of information only and does not amend, extend or alter the coverage of the policies it lists. It does not update when a policy renews or ends early, so the old certificate alone cannot tell you which of these happened.
| Situation | What your file shows | What happened | What to ask for |
|---|---|---|---|
| Renewal not sent | A certificate past its expiration date | The policy renewed with no break; the new certificate never reached you | A certificate for the renewal term |
| Lapse | No renewal, or a renewal that starts after the old expiration date | Days passed with no policy shown on any certificate | The renewal certificate and the gap dates, in writing |
| Cancellation | A certificate that still shows a future expiration date | The policy ended before that date | The cancellation date and any replacement policy, in writing |
The first is a paperwork problem. The other two are coverage problems, and a cancellation may never be announced to you.
Check one line at a time. Each coverage line on an ACORD 25 carries its own policy dates. General liability can run to next year while the umbrella or workers' comp ends this month. The certificate is only as current as the earliest line your subcontract requires.
2. Confirm with the producer, in writing
The producer is the agency in the PRODUCER box. It issued the certificate and can answer fastest. Email the producer and copy the sub. Ask four questions:
- Was the policy renewed? Please give the new policy number and the effective and expiration dates for each line.
- Was there any period between the old expiration date and the new effective date with no policy in force?
- Was the policy cancelled before its printed expiration date? If so, on what date?
- Please send a current ACORD 25 for the renewal term, with our company as certificate holder and the endorsement pages our subcontract requires.
A phone call is fine for speed. The file still needs the written answer.
For workers' comp, some states publish coverage data. New York's Workers' Compensation Board runs an employer coverage search fed by insurers' proof-of-coverage filings, updated daily. Florida's Division of Workers' Compensation tells contractors to get one of three proofs before a sub starts: the policy's information page, a screen print from its Proof of Coverage database, or a certificate plus written confirmation from the producer or carrier. A lookup is a second source. It does not replace the certificate your subcontract asks for.
3. Binder or certificate: ACORD 75 vs ACORD 25
If the renewal policy has not been issued yet, the producer may send a binder. The standard ACORD binder form is the ACORD 75, Insurance Binder. The certificate you usually collect is the ACORD 25, Certificate of Liability Insurance. They are different documents.
- A binder is temporary insurance. Oregon's insurance code treats a binder as a contract for temporary insurance that includes the usual terms of the policy it binds (ORS 742.043).
- A certificate is information only. The ACORD 25 states that it confers no rights on the certificate holder and does not change the coverage of the policies listed.
- A binder has a short life. In Washington, a binder is not valid beyond the issuance of the policy or 90 days from its effective date, whichever comes first, unless the insurance commissioner approves an extension (RCW 48.18.230). Oregon requires the policy within 90 days of the binder, with limited exceptions such as a written extension from the state (ORS 742.043). Other states set their own rules.
When you receive a binder, record its insurer, coverages, limits and dates, and set a follow-up for its end date. When the policy issues, ask for the ACORD 25 for the new term and review it like any other certificate.
4. Check what your subcontract says about site access and payment
The certificate does not decide whether the sub keeps working or gets paid. The subcontract does. AIA's 2017 forms show four kinds of clause to look for:
- When certificates are due. AIA's owner-contractor insurance exhibit (A101–2017 Exhibit A, §A.3.1.1) asks for certificates before work starts, at each renewal or replacement of a required policy, and on written request.
- Who must give notice of a lapse. A201–2017 §11.1.4 requires the contractor to notify the owner within three business days of learning of an impending or actual cancellation or expiration of required insurance.
- Stopping the work. The same section gives the owner the right to stop the work until replacement coverage cures the lapse, unless the owner caused it. AIA's subcontract, A401–2017, adopts A201–2017 as its general conditions (§1.3). Its Article 2 passes the contractor's obligations to the owner down to the sub and gives the contractor the owner's rights against the sub, to the extent they apply to the sub's work.
- Payment and default. Under A201–2017 §9.10.2, final payment and remaining retainage are not due until the contractor submits a certificate showing that insurance required to stay in force after final payment is in effect. A401–2017 §3.5 is a default clause: if the sub does not start correcting a default within five working days after notice, the contractor may remedy it and withhold the reasonable cost from payments.
Your subcontract may change or delete any of these, so read your own. Workers' comp can also land on the GC by statute. In Florida, the contractor is liable for workers' compensation for a sub's employees on the contract work unless the sub has secured it, and the contractor must require subs to provide evidence of workers' comp insurance (Fla. Stat. §440.10(1)(b)–(c)).
Write the decision down: who decided whether the sub stays on site and whether the next payment goes out, on what date, and under which clause.
5. Record the gap dates
If the renewal starts after the old policy ended, record:
- The coverage line: general liability, auto, umbrella or workers' comp.
- The old expiration date and the new effective date.
- The days the sub's crew worked on your site in that window, from daily logs or sign-in sheets.
- What you paid the sub for work in that window.
- The producer's written answer.
These dates matter after the project ends, at your own workers' comp premium audit. Where NCCI's Basic Manual applies, Rule 2-H asks the contractor for satisfactory evidence that the sub had workers' comp in force covering the work it performed: a certificate, a certificate of exemption or a copy of the policy. Without it, the insurer can charge premium on the sub's payroll, or on the full price of its work when there are no payroll records. In a 2013 final order, Tennessee's Department of Commerce and Insurance upheld $17,452 in added premium against a home builder whose sub's workers' comp certificates were in force for only two months of the builder's policy year. More in premium audits and subcontractor certificates.
6. Review the renewal certificate as a new document
A renewal is a new policy period. Compare it with the old certificate, not just with your minimums: a limit can drop or an endorsement can disappear. Check:
- The named insured still matches the entity on your subcontract.
- The insurer, policy number and dates for every line.
- Every limit against your minimums.
- Additional insured for ongoing and completed operations, with the endorsement pages if your subcontract requires them. AIA's Exhibit A, for example, asks for additional-insured coverage no less than ISO forms CG 20 10 07 04 and CG 20 37 07 04.
- Completed operations after the job. AIA's Exhibit A asks for a certificate showing completed-operations coverage continues with the final payment application, and again at each renewal until the required period ends.
For the box-by-box read, use how to read an ACORD 25. If the renewal comes back below a minimum, follow what to do when a COI comes back short.
7. Send a final notice if nothing comes back
If the producer and the sub go quiet, send one final notice to the sub's signer and copy the producer. Keep it factual: the project, the coverage line and the date it ran out; the certificate and endorsement pages you need; the date you need them by and where to upload them; the subcontract clause that applies, quoted; and who to contact.
Then stop the automated chase and give the item to a person. For ready-to-edit wording, use the final-notice email in COI request email templates.
Why a cancellation can reach you late
A cancelled policy can sit behind a certificate that still shows a future expiration date:
- The ACORD 25 cancellation box says notice will be delivered in accordance with the policy provisions. It does not promise notice to the certificate holder.
- The Texas Department of Insurance explains that a person has a legal right to notice of cancellation only if the person is named in the policy or an endorsement, and the policy, endorsement or a law requires the notice.
- AIA's instructions for G715 note that many liability policies do not require the insurer to notify parties other than the primary insured.
If you need notice from the insurer, ask the producer for an endorsement that names you and requires it. Otherwise, you learn of a cancellation from the sub, if the subcontract requires the sub to tell you, or from the producer when you ask.
Common questions
Does an expired certificate mean the subcontractor has no insurance?
No. The certificate shows the policy dates as of the day it was issued, and the policy may have renewed since. Ask the producer for the renewal certificate before you treat it as a lapse.
Can I keep paying a subcontractor whose COI expired?
The certificate does not answer that; your subcontract does. Read its payment, insurance and default clauses, make the decision, and record who made it, when, and under which clause.
How long is an insurance binder good for?
It depends on the state and the binder. In Washington, a binder ends when the policy issues or 90 days after its effective date, whichever comes first, unless the insurance commissioner approves an extension. Oregon requires the policy within 90 days of the binder, with limited exceptions.
Will the insurer tell me if the sub's policy is cancelled?
Not necessarily. In Texas, a certificate holder has a legal right to notice only if it is named in the policy or an endorsement and the policy, endorsement or a law requires the notice. The ACORD 25 itself says notice will be delivered under the policy provisions.
What if only one coverage line expired?
Treat that line as expired and chase it. Each line on an ACORD 25 has its own dates, so general liability can be current while the umbrella or workers' comp has ended.
Why do the gap dates matter after the project?
They matter at your own workers' comp premium audit. Under NCCI's Basic Manual Rule 2-H, the contractor must show the sub had workers' comp in force covering the work it performed. If the certificates miss part of that time, the insurer can charge you premium for that sub's work.
Where SubLien fits
SubLien reads each ACORD 25 with AI and keeps every coverage line's own expiry date. Status, reminders and the calendar follow the first line to run out, and the reminder names that line. Reminders go to the sub before the date; you can turn on a copy to the agent named on the certificate when it shows an email address. The review screen shows what changed from the previous certificate. Certificate history links the original and the replacement, with the reviews and messages sent through SubLien. A renewal stays pending until a named person on your team reviews it.
SubLien does not confirm coverage with the insurer, decide whether a sub may work, or hold payments. See COI tracking.
Primary sources
- Texas Department of Insurance — filed ACORD 25 specimen: information-only statement and cancellation box.
- Texas Department of Insurance — certificates of insurance FAQ: when a certificate holder has a legal right to notice of cancellation.
- Iowa Administrative Code 191—20.72: names ACORD Form 75 as a binder form.
- Washington RCW 48.18.230: how long a binder is valid.
- Oregon ORS 742.043, in chapter 742: binders as temporary insurance.
- AIA — instructions for G715–2017: cancellation notice and A201–2017 §9.10.2.
- AIA — A101–2017 Exhibit A sample: certificate timing, completed operations, ISO additional-insured forms.
- AIA A201–2017 sample, posted by the University of Maine System: §11.1.4 notice and stop-work right, §9.10.2 final payment.
- AIA — A401–2017 sample: §1.3, Article 2 flow-down, §3.5 contractor's remedies.
- Florida Statutes §440.10: contractor liability for an uninsured sub's employees.
- Florida Division of Workers' Compensation — employer FAQ: proof of a sub's coverage.
- New York Workers' Compensation Board — employer coverage search: insurer-filed coverage data, updated daily.
- Tennessee Department of Commerce and Insurance — BC Developers final order (2013): NCCI Rule 2-H and added premium for a sub's coverage gap.