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The blog · Post 05 · October 2026

The certificate says you're covered. The policy decides.

A certificate of insurance proves a policy existed the day it was printed. It can't add a general contractor to your policy or promise notice of cancellation, and since September 12, 2026, Arizona law says so. What a certificate does, what actually protects the general contractor, and what to send instead.

The routine

Same as last time.

Every subcontractor knows the routine. You win the job, the general contractor's office sends a request, and someone at your shop emails your agent: "Need a COI for the Main Street project, same as last time." A PDF comes back within the hour, you forward it, and the job starts.

That PDF matters less than most people think. A certificate of insurance is a summary. It is not the policy, and it cannot change the policy. When a claim arrives, the insurer reads the policy and its endorsements. It does not read the certificate.

Arizona put that into law this year. If you work in Arizona, or for a general contractor whose contract template came from there, here is what changed and what to do about it.

The form

What a certificate is.

A certificate of insurance, or COI, is usually a one-page form called the ACORD 25. It lists your insurers, policy numbers, policy dates and limits for general liability, auto, umbrella and workers' comp, and it names a "certificate holder," usually the general contractor or the property owner who asked for it.

The form is honest about what it is. Near the top, in capital letters, it says it is "issued as a matter of information only and confers no rights upon the certificate holder," and that it "does not affirmatively or negatively amend, extend or alter the coverage afforded by the policies below."

In plain English: the certificate tells the general contractor that you had a policy on the day it was printed. It does not make them part of that policy, and it does not promise the policy will still be there next month.

Arizona

What Arizona changed on September 12.

Arizona's legislature passed HB 2996 this spring. The governor signed it on June 4, 2026, as Chapter 122, and it adds a new section to the insurance code, A.R.S. § 20-443.03. The bill has no emergency clause, so it took effect on the session's general effective date, September 12, 2026. In short, the new section says:

  • A certificate of insurance is not an insurance policy. It does not amend, extend or alter the coverage the policy provides, and it gives no rights beyond those the policy states.
  • Nobody may prepare, issue, request or require a certificate that contains false or misleading information about the policy, that alters or extends its coverage, or that claims the policy complies with the insurance or indemnification requirements of a contract.
  • Anyone other than the policyholder is entitled to notice of cancellation, nonrenewal or a material change only if the policy or an endorsement gives that right. Typing "30 days' notice" on the certificate does not create it.
  • The director of the Department of Insurance and Financial Institutions can order a person who violates the section to stop, and fine them up to $1,000 per violation.
  • It applies to certificates issued for property and casualty risks located in Arizona, wherever the policyholder, insurer, agent or requester is located, and to contracts and addenda entered into on or after the effective date.

Most of this describes how certificates were always supposed to work. What changed is enforcement. In Arizona, a general contractor can no longer require a certificate that says something the policy doesn't, and the fine applies to whoever prepares, issues, requests or requires one, whether that is an agent or the general contractor asking for it.

Texas

Texas has had the same rule since 2011.

Texas got there first. Chapter 1811 of the Texas Insurance Code, added in 2011, says a certificate form must be filed with and approved by the Texas Department of Insurance before anyone issues it for a Texas risk. A Texas certificate may not alter the notice terms of a policy, and it may not even refer to requirements in a contract other than the insurance policy itself, "including a contract for construction or services."

So if your general contractor's Texas office sends back your certificate asking you to add "coverage per contract section 11.2," the honest answer is that the law doesn't allow it. What they need is the endorsement.

Endorsements

What actually protects the general contractor.

The general contractor wants two things from your policy: to be covered for claims that come from your work, and to know if your coverage ends. Both live in endorsements, the add-on pages that change what a policy does.

Additional insured endorsements add the general contractor (and often the owner) to your general liability policy for claims arising from your work. The two most common standard forms are:

  • CG 20 10, which covers the additional insured for your ongoing operations, meaning while you are still on the job.
  • CG 20 37, which covers the additional insured for your completed operations, meaning after you have finished and left.

The split matters. Insurance Services Office revised CG 20 10 in 2001 to exclude injury or damage that happens after the work is done, and introduced CG 20 37 to restore that completed-operations coverage. A construction-defect claim that shows up a year after you leave the job is a completed-operations claim. If the general contractor is only on CG 20 10, that claim falls outside their additional insured coverage, no matter what the certificate says.

A waiver of subrogation is the second piece. After paying a claim, an insurer can normally try to recover the money from whoever caused the loss. A waiver of subrogation endorsement gives up that right against a named party. Contracts often require it on general liability, auto and workers' comp.

A notice of cancellation endorsement is the third. Policies notify the policyholder, not the certificate holder, when coverage is cancelled. If your contract promises the general contractor advance notice, the policy needs an endorsement that says so. Under Arizona's new law, that endorsement is the only way the promise means anything.

Your side

Why this matters for a subcontractor.

It can look like the general contractor's problem. It isn't. Most subcontracts include an indemnity clause and an insurance clause. If the contract requires you to name the general contractor as an additional insured for completed operations, and your policy doesn't, the general contractor can come after you for breach of contract. That claim may not be covered by your own policy either.

The good news is that this is one of the easier gaps to close. Additional insured, waiver of subrogation and notice endorsements are routine. Many policies carry blanket versions that apply when a written contract requires them, but the wording varies by carrier: some require the contract to be signed before the loss, and some cover ongoing operations only. The work is in reading the contract and checking the policy before the job, not after the claim.

Before you bid

Five things to do before your next bid.

  1. Read the insurance clause before you price the job. It usually sits in an exhibit near the back of the subcontract. Look for "additional insured," "completed operations," "primary and non-contributory," "waiver of subrogation" and "notice of cancellation," and note the limits.
  2. Send your broker the clause, not just the request. A good certificate request includes a copy of the contract's insurance exhibit. Your broker can tell you whether your policy already meets it or which endorsements to add.
  3. Send the endorsement pages. When a general contractor wants proof, send the certificate and the endorsement pages that do the work. Arizona's law makes clear that the certificate alone can't.
  4. Hold your own subs to the same standard. If you hire lower-tier subcontractors, collect their endorsement pages, not just their certificates. Their gap becomes yours.
  5. Calendar every expiration date. A certificate goes stale the day the policy renews or cancels. Request updated certificates before your subs' policies expire, and send yours before the general contractor asks.

A certificate is a receipt. The policy is the product. Make sure the product is what the contract asked for.

Hablamos español

¿Prefieres hablar en español?

¡Sí, hablamos español! Un corredor licenciado revisa contigo la cláusula de seguros de tu contrato y te dice qué endosos necesitas, no solo qué certificado enviar. Llama al (888) 585-9910.

New Decade Insurance is an independent brokerage built by agents who have been writing insurance since 2005. Licensed in CA, TX, FL and AZ.

This article is general information, not legal or insurance advice, and not a quote. Coverage depends on the terms, conditions and exclusions of the policy issued, on the endorsements attached to it, and on the law of the state where a claim arises. Arizona and Texas law is summarized as of October 2026; confirm current requirements with the state or your broker, and have your attorney review contract language.

Sources

Where the rules come from.

  • Arizona Legislature, HB 2996, Laws 2026, Chapter 122: A.R.S. § 20-443.03, approved by the governor June 4, 2026; civil penalty up to $1,000 per violation
  • Arizona Legislature, Session Laws: general effective date for the 2026 session, September 12, 2026
  • Arizona Society of CPAs, ASCPA Advocate: 2026 Legislature adjourns sine die on June 13
  • Texas Department of Insurance, Certificates of insurance FAQ: Insurance Code chapter 1811 (2011), §§ 1811.052, 1811.154, 1811.155
  • ACORD 25 Certificate of Liability Insurance, as filed with the Texas Department of Insurance
  • IRMI, 2013 ISO Additional Insured Endorsements: Putting the Changes into Context for the Construction Industry (the 2001 CG 20 10 revision and CG 20 37)
  • IRMI, Additional Insured Status and Waivers of Subrogation
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