Insurance Certificate Compliance Check

Compares Access Agreement insurance requirements to COI and endorsement evidence to produce a defensible compliance determination with actionable deficit remediation.

Prerequisites

1. Access Agreement (final) with insurance clause, exhibits, and amendments
2. COIs for all required lines: CGL, auto, WC/EL, umbrella, specialty
3. Endorsement copies: AI, completed-ops AI, primary/non-contributory, waiver of subrogation, umbrella schedule
4. Recipient legal names, required AI entities, project scope
5. Access dates, locations, post-completion carry-forward period
6. Governing law / jurisdiction
7. Delivery recipients and privilege instructions

Quick Start

1. Extract all insurance requirements from the agreement into a requirements matrix
2. Run COI baseline checks against each requirement
3. Verify endorsement-level evidence for every core element — COI text alone is non-binding
4. Assess risk and coverage-structure gaps
5. Apply jurisdiction-specific considerations
6. Output compliance determination with deficit list

Workflow

Step 1: Build Requirements Matrix

Extract from agreement into normalized rows:

Category	Extract	Normalize to
Coverage types	CGL, auto, WC/EL, umbrella, specialty	[line]: [form/limits/scope]
Limits	Occurrence, aggregate, products-completed, per location/project	Numeric minimums + frequency
AI scope	Named entities and affiliates	Exact legal names + ongoing/completed
Priority terms	Primary/non-contributory	Which policies/lines
Waiver of subrogation	Which lines require waiver	CGL/WC/auto/property
Notice/ratings	Cancellation notice, AM Best, insurer status	Required evidence
Special clauses	Exclusions, endorsements by form number	Must be checked

Flag vague clauses (acceptable, sufficient, as required by owner) as Attorney Clarification Required.

Step 2: COI Baseline Checks

These are information-only — not proof of coverage:

1. Named insured matches recipient entity exactly (name + suffix + related entity logic)
2. Policy period covers access window
3. Required coverages and limits appear in correct fields
4. Occurrence vs claims-made confirmed
5. Aggregate designations align (per occurrence, per location, per project)
6. Producer/broker contact present
7. Red flags: expired/expiring policies, wrong entity, missing policy numbers

If incomplete, set Conditionally Compliant and list missing documents.

Step 3: Endorsement Verification

COI text alone is non-binding. Require endorsement-level evidence for each:

Element	Required	Common failure
Additional insured	Endorsement naming exact entities	Blanket AI with entity mismatch
Completed-ops AI	Separate completed-ops endorsement	Only ongoing AI provided
Primary/non-contributory	PNC clause/endorsement for AI	PNC on COI only
Umbrella alignment	AI/PNC in underlying + umbrella schedule	No schedule showing extension
Waiver of subrogation	Endorsement on required lines	Narrative in COI only
Cancellation notice	Enforceable mechanism documented	Reliance on ACORD boilerplate only

Step 4: Risk and Coverage-Structure Checks

1. Verify minimum limits vs exposed values per line and project
2. Compute combined limits where umbrella augments GL/auto/EL
3. Check for coverage-exclusion conflicts (geographic, type-of-work, access-specific)
4. Review deductibles/SIR if high-risk or large retention (from declarations/broker attestation)
5. Confirm insurer rating with explicit evidence

Step 5: Jurisdiction Adaptation

Apply [VERIFY] to all jurisdiction-specific conclusions:

• New York: Construction gravity-risk and labor-law exclusions [VERIFY]
• Texas: Anti-indemnity impact on AI enforcement [VERIFY]
• California: Active-negligence/AI enforceability constraints [VERIFY]
• Florida: Policy disclosure and insurer-info rights [VERIFY]

If governing law is uncertain, mark all jurisdictional conclusions as requires legal verification.

Step 6: Output

Result: [Compliant | Conditionally Compliant | Non-Compliant]
Jurisdiction: [state]
Coverage period tested: [start] to [end]
Review confidence: [High | Medium | Low]

Requirements Matrix:
- Requirement | Evidence | Status | Finding | Deficiency
- ...

Escalation: [In-house counsel / Risk manager / Coverage counsel]
Access decision: [Recommend allow / conditional / deny pending docs]

Use entity-name exactness and numeric precision ($1,000,000 each occurrence, CG 20 37).

Critical Guardrails

• COI statements are documentary indication, not contractual proof
• Never state "fully covered" without endorsement/policy support
• Certificate holder ≠ additional insured — never conflate
• Never infer AI scope from checkbox or Description of Operations alone
• For each deficit, provide precise broker instruction: exact endorsement form/edition and deadline
• Track status as confirmed, indicated-not-verified, or not shown
• This is a risk-control assessment, not a coverage legal opinion
• Include attorney review requirement before operational reliance
• If access allowed with unresolved deficits, document written exception and mitigation
• If anti-indemnity/statutory effects drive outcome, escalate immediately
• Use [VERIFY] on all uncited or uncertain authority claims