Roofing subcontractors
Roofing subcontractor COI requirements
Roofing has the highest first-review defect rate of any trade in Pikorua Security's benchmark. Roofers buy insurance in a hard market, so their policies arrive loaded with restrictions: hot work and torch-down exclusions, height limits, residential exclusions and endorsements that quietly remove the completed operations coverage a GC needs when a roof leaks two winters later.
Roofing audit
Ridgeline Roofing Inc.
Riverside Commons Phase 2
- CGL policy
- GL 7741-0093-22
- AM Best
- A- VII
- Carrier
- Prairie States Indemnity Co.
- DeficientCG 20 37
Completed operations AI not attached. Only CG 20 10 04 13 on file.
- DeficientManuscript
Torch-down exclusion (RF 104) conflicts with spec section 07 52 00.
- DeficientHeight
Three-story limitation on a five-story building.
- of roofing subcontractor COI packets are deficient on first review
- 84%
- of roofing subcontractor COI packets are deficient on first review
- Pikorua Security 2026 Benchmark
- trade rank by defect rate, 13 points above the all-trade average
- 1 of 14
- trade rank by defect rate, 13 points above the all-trade average
- Pikorua Security 2026 Benchmark
- of subcontractor and vendor COIs contain material coverage deficiencies or missing endorsements on first review
- 71%
- of subcontractor and vendor COIs contain material coverage deficiencies or missing endorsements on first review
- AGC Risk Committee Audit
- of COIs claiming additional insured status fail to attach the CG 20 37 completed operations endorsement
- 64%
- of COIs claiming additional insured status fail to attach the CG 20 37 completed operations endorsement
- IRMI Construction Risk Survey
Typical exhibit
Typical roofing insurance requirements
- Rules in template
- 14
- Hazard tier
- Severe
| Coverage | Typical limit | What to check |
|---|---|---|
| Commercial general liability (CG 00 01, occurrence) | $1,000,000 each occurrence / $2,000,000 general aggregate | Reject claims-made CGL forms for roofing; a leak that appears after the policy lapses would find no coverage. |
| Products-completed operations aggregate | $2,000,000 | Water intrusion and wind uplift claims arrive after turnover. Completed operations is the coverage that actually pays on most roofing losses. |
| Business auto liability | $1,000,000 combined single limit | Covers crew trucks and trailers hauling kettles and materials. Hired and non-owned autos must be included. |
| Umbrella / excess liability | $10,000,000 each occurrence and aggregate | Fall severity and fire exposure push roofing to the top umbrella tier on most GC exhibits. Must follow form, including over completed operations. |
| Workers compensation / employer's liability | Statutory / $1,000,000 each accident, $1,000,000 disease each employee, $1,000,000 disease policy limit | Roofing WC is among the most expensive class codes, which is why some roofers lean on uninsured sub-tier crews. Ask for the sub-tier's WC too. |
| Inland marine (contractor's equipment) | Actual cash value of kettles, hoists and torches | Protects the sub's equipment so a theft or fire on your site does not become a dispute over your builder's risk. |
Endorsement checklist
Forms to see attached, not just checked
- CG 20 10Additional insured, ongoing operations
- CG 20 37Additional insured, completed operations
- CG 20 01Primary and noncontributory
- CG 24 04Waiver of subrogation on general liability
- WC 00 03 13Waiver of subrogation on workers compensation
- CA 20 48Designated insured for covered autos liability
- CG 25 03General aggregate applies per project
Exclusion watchlist
Exclusions that void roofing coverage
- Red flag
Hot work / torch-down roofing exclusion
Carrier manuscript forms that exclude fire and property damage from torches, kettles and heat-welded membranes, sometimes extending into completed operations. If the spec calls for modified bitumen or built-up roofing, this exclusion removes the very exposure you are transferring. Some versions restore coverage only when a fire watch and post-work monitoring are documented.
- Red flag
Height limitation exclusion
Excludes work above a stated number of stories or feet. A sub with a three-story limit on a five-story building is uninsured for the whole scope even though the COI shows full limits.
- Red flag
Residential, condominium or tract housing exclusion
Common on roofing policies. On mixed-use or condominium projects the residential portion may be excluded outright, which a certificate will never show.
- Red flag
CG 21 86 Exclusion, Exterior Insulation and Finish Systems
Roofers who flash into EIFS parapets or install adjacent cladding can trigger this exclusion. Water damage behind EIFS is one of the costliest defect claims in construction.
- Red flag
CG 22 94 Exclusion, Damage to Work Performed by Subcontractors on Your Behalf
Roofers often sub out sheet metal and flashing. With CG 22 94 attached, damage to the roof caused by the sheet metal sub-tier is not covered.
Read the CG 22 94 guide
Why roofing COIs fail more than any other trade
Roofing is the trade where the certificate and the policy are furthest apart. Carriers that write roofers price for falls, fire and water, and they control that risk with endorsements rather than premium alone. The ACORD 25 shows the limits and a Y in the ADDL INSD column; it does not show a torch-down exclusion, a three-story height limit or a residential exclusion. In Pikorua Security's benchmark, roofing packets fail first review more often than any other trade.
The single most expensive gap is completed operations. Roofing claims are overwhelmingly post-completion: a membrane seam fails, a drain backs up, flashing lets go in a windstorm. If the GC is named only on CG 20 10 04 13 (ongoing operations), it has no additional insured status when the leak claim arrives. Require CG 20 37 alongside CG 20 10, and require the sub to keep completed operations coverage in force for the period your subcontract specifies.
Reading a roofing endorsement packet
Ask for the full forms and endorsement schedule, not just the AI pages. Pikorua Security parses the schedule of forms on the declarations and matches each form number and edition against your roofing rule template, which runs 14 checks. The checks that catch the most roofing deficiencies are below.
- Hot work or heat-application exclusions, and whether any safety warranty (fire watch, CERTA-trained torch applicators) is attached as a condition.
- Height or story limitations compared against the project's building height.
- Residential, condominium or tract housing exclusions on mixed-use projects.
- CG 20 37 present, edition matched to CG 20 10, and not limited to a schedule that omits your project.
- CG 22 94 or CG 21 39 attached, which gut coverage for sub-tier work and contractual indemnity.
Setting a roofing exhibit that holds up at tender
Write the roofing exhibit as a higher tier than your standard sub requirements: a larger umbrella, explicit completed operations duration, and a prohibition on hot work exclusions when the spec includes torch-applied or kettle work. Put the rule in the exhibit rather than in an email; a carrier evaluating a tender will read the subcontract, not the correspondence.
In Pikorua Security, the roofing template sets these rules once per project. When a roofer's packet comes in with a torch-down exclusion, the deficiency notice goes to the roofer and its broker with the clause cited, and the Procore commitment stays on payment hold until a compliant endorsement arrives.
How to verify a roofing sub's COI
A manual review of one COI and its endorsement packet takes 25 to 40 min (CFMA Time Study). These are the six checks, in the order Pikorua Security runs them.
- 1
Match the named insured to the subcontract
Compare the named insured on the ACORD 25 with the legal entity that signed the roofing subcontract, including the LLC or Inc. suffix. A trade name or DBA is not the contracting entity, and additional insured coverage follows the policy's named insured.
- 2
Check limits against your roofing exhibit
Confirm commercial general liability of $1,000,000 each occurrence / $2,000,000 general aggregate, an umbrella of $10,000,000 that follows form over CGL, auto and employer's liability, and statutory workers compensation. Then confirm inland marine is evidenced, because it does not appear on a standard ACORD 25.
- 3
Read the endorsement pages, not the checkboxes
A Y in the ADDL INSD or SUBR WVD column is not an endorsement. Confirm CG 20 10, CG 20 37, CG 20 01, CG 24 04, WC 00 03 13, CA 20 48 and CG 25 03 are attached as forms, and that the ongoing and completed operations forms share the same edition date.
- 4
Scan the schedule of forms for roofing exclusions
Look for hot work / torch-down roofing exclusion, height limitation exclusion, residential, condominium or tract housing exclusion, CG 21 86 Exclusion, Exterior Insulation and Finish Systems and CG 22 94 Exclusion, Damage to Work Performed by Subcontractors on Your Behalf. None of these appear on the certificate; they sit in the declarations schedule of forms and the endorsement pages.
- 5
Check carrier ratings and policy dates
Confirm each carrier is rated A- VII or better by AM Best and that no policy expires before the roofing scope and its completed operations period are finished. Set renewal reminders at 60, 30, 15 and 0 days.
- 6
Hold payment and site access until resolved
Keep the roofing sub's pay applications and jobsite badges on hold until every finding is resolved, then file the verified packet so it is ready if you ever need to tender a claim.
Try it
Is this roofing COI compliant?
What the packet from Ridgeline Roofing Inc. shows
04 13 or later edition
OKEdition matches CG 20 10
GapOn a torch-applied spec. Red flag if present.
GapStory or feet limitation. Red flag if present.
OKFollows form over completed ops
OKBoth GL and WC
OK
Switch on = present in the packet. Switch off = missing.
Deficient: 2 findings
CG 20 37 for completed operations
No AI status when the roof leaks after turnover.
Hot work or torch-down exclusion
Fire from torch work is excluded.
Pikorua Security would send a deficiency notice to the sub and its broker citing each item, and hold payment until a corrected endorsement arrives.
Questions
Roofing COI questions
Why does roofing have the highest COI defect rate?
Do I need CG 20 37 from a roofing subcontractor?
What is a hot work exclusion on a roofing policy?
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