ACORD Certificate of Insurance Form Explained

Short answer: the ACORD certificate of insurance is a standardized snapshot of coverage that already exists. In Texas it is deemed approved for use once filed with TDI, and it is legally barred from saying anything the underlying policy does not say. Reading it correctly means reading the policy behind it, not just the boxes.

Many insurance compliance disputes in Texas construction, vendor onboarding, and property management run through this one page. A general contractor rejects a subcontractor's certificate. A procurement analyst insists on wording. An agent says the law will not allow it. Everyone is looking at the same grid of boxes and drawing different conclusions from it.

The governing rules are explicit even when the operational dispute is not. Texas Insurance Code Chapter 1811 and the rules at 28 Texas Administrative Code Sections 5.9370 through 5.9376 say what may go in the form. This guide walks the form from the top and cites the rule for each part.

What ACORD is, and why the form is standard

ACORD is the Association for Cooperative Operations Research and Development, a standards body for insurance data and forms. It is not a regulator and it is not an insurer. Its value is that a certificate looks the same coming from any agency in the country, so a reviewer can find the general liability limits in the same place every time.

Texas gives that standardization legal effect. Section 5.9375(a) provides that a standard certificate of insurance form promulgated by ACORD, the American Association of Insurance Services, or the Insurance Services Office is deemed approved on the date the form is filed with TDI. Insurance Code Section 1811.103 is the statutory basis. An authorized user may use the standard form without making a separate filing, and Section 5.9375(c) defines an authorized user as someone authorized by the company or its designee to use the company's approved form, or someone authorized by ACORD, AAIS, or ISO to use the appropriate standard form.

The practical consequence: nobody needs to argue about whether the ACORD certificate is acceptable in Texas. What people argue about is the content, and the content rules are separate.

The disclaimer at the top is the operating rule

The paragraph most people skim is the one that governs everything below it.

Section 5.9376(a) requires that a certificate contain the phrase "for information purposes only" or similar language, or state that the certificate confers no rights or obligations other than those conveyed by the referenced policy, and that the terms of the policy control over the terms of the certificate.

That is a rule about the document's legal weight, written into the document. It reflects Insurance Code Section 1811.051, under which no certificate filed with TDI can say more than what is in the related policy.

So when a certificate holder reads the disclaimer as a hedge, they have it backwards. The disclaimer is the state telling everyone how to read the rest of the page. A certificate is evidence of coverage. It is not the coverage, and it is not a contract between the insurer and the holder.

Reading the form box by box

Producer

The agency that issued the certificate, with contact information. Section 5.9372(b)(2) requires that a filed certificate form carry a form number and edition date for identification, which is why you can tell one revision of the form from another.

One point worth knowing: TDI says a property and casualty agent or surplus lines agent must hold an appointment with the managing general agent or insurance company that issues the policy in order to deliver a certificate to a customer, citing Insurance Code Section 4001.201 and 28 TAC Section 19.905. If a certificate arrives from an agency with no relationship to the carrier shown, that is a question worth asking.

Insured

The named insured as it appears on the policy. Not the trade name, not the d/b/a unless the policy carries it, not the parent company. A mismatch between this box and the entity named in the contract can cause a rejection. Fixing it may mean fixing the policy, not the certificate.

Insurers affording coverage and NAIC number

Each carrier gets a letter, and the letters map to the policy rows below. The carrier name and NAIC number are identifiers, not proof of admitted status by themselves. Use them to verify the insurer through TDI when admitted or surplus lines status matters for guaranty association protection or contract compliance.

Coverages, limits, and policy numbers

The main grid, one row per policy, with effective and expiration dates and the limits that apply. Two things reviewers should check and often do not.

Aggregates are not reserved for one certificate holder. A $2,000,000 general aggregate applies under the policy terms across covered occurrences during the applicable policy period. The certificate does not set aside that amount for the holder reading it.

Dates have to cover the work, not the moment of review. A certificate valid today does not mean coverage exists on the completion date, and renewal evidence is a separate request.

TDI also restricts the terminology that may appear here. On the general liability section, terms like Broad Form Property Damage and Comprehensive General Liability may not be used, because TDI's position is that these are not common to general liability policies, and Insurance Code Section 1811.102 bars requiring an agent to certify coverage that is not available in the line or type referenced on the form. On the auto section, Basic Automobile and Comprehensive Auto get the same treatment. On the workers compensation section, a reference to stop gap liability is not permitted, because that coverage does not apply to Texas workers compensation policies. Nonsubscribers should read the stop gap insurance guide rather than expecting the certificate to solve it.

There are more granular rules in the same vein. TDI says explosion, collapse, and underground perils should be listed separately unless the policy provides them on a combined basis, and that terms like independent contractors' coverage, blowout and cratering, and bodily injury and property damage due to explosion or collapse may not appear unless the exact terms are in the policy.

The additional insured and subrogation waived columns

These two check boxes carry most of the compliance weight on the form, and TDI's guidance on them is short enough to quote in practice.

Check the Additional Insured box if the policy includes an endorsement that names the certificate holder as an additional insured. Check the Waiver of Subrogation box if the policy includes a waiver of subrogation endorsement that names the certificate holder.

The corollary is what generates friction. If the policy carries only a blanket additional insured endorsement, the certificate may state that the blanket endorsement exists, but it may not name the holder as an additional insured. TDI cites Sections 1811.051(a), 1811.054, and 1811.152. The same analysis applies to a blanket waiver of subrogation, citing Sections 1811.051(a) and (b), 1811.054, and 1811.152.

This is not an agency being difficult. Section 5.9376(b)(2) says a certificate may not confer new or additional rights beyond what the referenced policy or any executed endorsement provides. Checking a box does not create an endorsement. The additional insured versus certificate holder explainer covers the downstream consequences of getting this wrong.

Description of operations, locations, vehicles

The free-text box, and therefore the one with the most rules.

No importing the other contract. Section 1811.154 prohibits a reference to a legal or insurance requirement contained in a contract other than the underlying insurance contract, including a contract for construction or services. Section 5.9376(b)(5) restates it and adds that a certificate may refer to language in the insurance contract but may not refer to, describe, explain, or define obligations under any other contract.

A job or contract number is fine, for identification. TDI says yes if the number is listed for identification purposes only, and no to language such as "the insurer provides coverage in accordance with the terms of contract number blank" or similar wording.

Explanatory text comes from the policy. Section 5.9376(b)(4)(B) limits any explanatory information in a completed certificate to language in the referenced policy and any executed endorsements.

Sweeping coverage statements are out. TDI addressed a holder asking for a broad statement that there are no limitations or exclusions for residential construction exposure. The answer was no, unless the policy says exactly that and the addition has been filed and approved. A holder may instead ask the agent whether the policy contains specific language or a specific exclusion, or request a copy of the policy. TDI also treated a question like "does the policy cover all premises and operations?" the same way, noting that an approved form could provide a section to list covered premises and operations, and that under Sections 5.9376(b)(4)(A) and (B) a request for information must be specific, clear, and reasonable.

Certificate holder

The party receiving the certificate. Section 5.9371(b)(2) defines a certificate holder as a person, other than a policyholder, designated on the certificate as a holder or to whom the certificate was issued at the policyholder's request.

TDI took a specific question here worth knowing about. A holder asked to list, beyond its own name, the holder's corporate officers and employees, all subsidiaries, affiliated entities and assigns, and their officers and employees. TDI's answer: a certificate holder may not use the Certificate Holder box to imply or confer any new or additional rights beyond what the policy or an executed endorsement provides, citing Section 1811.153, and may not rely on the naming requirements of another contract to compel an insurer or agent to comply with that contract, citing Section 1811.154. TDI added that Section 1811.054 bars a person from requiring issuance of a certificate containing false or misleading information about the policy, and that violations carry civil penalties and possible injunction.

Cancellation

The form's cancellation language tracks the policy, and Section 1811.155 is why. A person may have a legal right to notice of cancellation, nonrenewal, material change, or similar notice only if the person is named within the policy or an endorsement, and the policy, endorsement, or a Texas law or rule requires that notice. A certificate may not alter those terms.

TDI's guidance does permit a certificate to contain a 30 day notice provision where the provision mirrors the policy, and the certificate may cite the applicable statute or rule. Section 5.9376(b)(6) adds that a certificate may not create a new or additional duty to notify, and that any statement about an existing duty is limited to language in the policy and executed endorsements.

What is not a certificate

The definition matters because it decides which rules apply.

Section 5.9371(b)(1) defines a certificate of insurance as a document, instrument, or record, including an electronic record, no matter how titled or described, executed by an insurer or agent and issued to a third person not a party to the insurance contract, as a statement or summary of property or casualty coverage. The term does not include an insurance binder or a policy form, or any document describing coverage that is merely promised or expected to exist in the future, whether titled an affidavit, an insurance verification form, or otherwise.

Two exclusions from Chapter 1811 come up often in practice. Section 1811.002(b) exempts a statement, summary, or evidence of property insurance required by a lender in a lending transaction involving a mortgage, lien, deed of trust, or other security interest as loan collateral. Section 5.9370(c) lists that exemption along with standard proof of motor vehicle liability insurance and several non property and casualty categories outside the scope of this guide. Section 5.9370(d) excludes negotiable or transferable marine certificates.

So the evidence of property insurance a mortgage lender wants at closing is a different document under a different rule than the certificate a general contractor wants before you mobilize.

Supplemental forms and affidavits

This is the request agents get most often and can least accommodate.

TDI addressed a holder asking an agent to complete a supplemental questionnaire in addition to the certificate. The answer was no: Chapter 1811 allows only TDI-approved certificates, and any form falling within the definition of certificate of insurance in Section 1811.001(3) must comply with Chapter 1811. TDI gave the same answer to an agent asked to complete an affidavit addressing contractual insurance requirements. In both cases TDI noted the agent may show the relevant policy language to the holder, and Section 5.9370(b) confirms that nothing in the rules prohibits a holder from requesting a copy of the policy or endorsements.

The productive move when this comes up is to offer the underlying evidence rather than argue about the form. Send the endorsement or relevant policy language and ask the reviewer whether that evidence satisfies the contract.

Penalties, and why they matter to holders

Chapter 1811 has teeth, and they point in both directions. TDI lists the possible penalties for noncompliance as cease and desist orders, injunctive relief, administrative penalties, civil penalties of up to $1,000 for each infraction, or any combination, citing Sections 1811.201 through 1811.204. Those penalties can apply to certificate holders, agents, insurers, and any entity defined under Section 1811.001(8).

Section 5.9376(c) also lets the commissioner disapprove or withdraw approval of a form that is misleading or deceptive, violates public policy or state law, requires an agent to certify coverage that is not available, or directly or indirectly requires the commissioner to make a coverage determination.

That last one is a useful frame. A certificate is not a coverage opinion. Anyone treating it as one is asking the document to do a job Texas law assigned to the policy.

A certificate review checklist

• Does the Insured box match the legal entity named in the contract?
• Is each carrier admitted or surplus lines, and does the contract care?
• Do the policy dates cover the full term of the work, including completion?
• Does the stated limit reach the contract total, and is an umbrella shown where one is needed?
• Is the Additional Insured box checked, and is there an endorsement naming the holder behind it?
• If the policy carries only a blanket endorsement, has the holder said whether it accepts that?
• Is Waiver of Subrogation checked on every line the contract names?
• Does the description box avoid importing the other contract's insurance requirements?
• Is any job or contract number there for identification only?
• Does the certificate carry the required for information purposes only language or its equivalent?
• Is the cancellation wording consistent with the policy rather than with the contract's wish list?
• Does the form carry a form number and edition date?
• Has anyone asked for an affidavit or questionnaire the agent is not permitted to complete?

Frequently asked questions

Is the ACORD certificate of insurance approved for use in Texas?

Yes. Under 28 Texas Administrative Code Section 5.9375, a standard certificate form promulgated by ACORD, AAIS, or ISO is deemed approved when filed with TDI. Insurance Code Section 1811.103 provides the statutory basis. A certificate for a risk located in Texas still must use a TDI-approved form regardless of where the holder is located.

What does the ACORD form's for information purposes only language actually do?

It states the operating rule. Section 5.9376(a) requires that phrase or similar language, or a statement that the certificate adds no rights or obligations beyond the referenced policy and that the policy controls. The disclaimer reflects Insurance Code Section 1811.051; it does not let the certificate override the policy.

When should the additional insured box be checked?

TDI says to check it when the policy includes an endorsement naming the certificate holder as an additional insured. If the policy has only a blanket additional insured endorsement, the certificate may describe that endorsement but may not name the holder as an additional insured on that basis alone.

Can the description of operations box reference my contract's insurance requirements?

No. Insurance Code Section 1811.154 prohibits a certificate from referencing a legal or insurance requirement in another contract. A job or contract number may identify the work, but the certificate cannot state that coverage complies with that contract.

Is an insurance binder the same thing as a certificate?

No. Section 5.9371 excludes an insurance binder and a policy form from its certificate definition. A binder can provide temporary evidence associated with coverage while a certificate summarizes coverage already provided by the referenced policy. They serve different purposes and are governed differently.

Why will my agent not add Broad Form Property Damage or Comprehensive General Liability to the form?

TDI says those terms are not common to current general liability policies, and Insurance Code Section 1811.102 bars requiring an agent to certify coverage unavailable in the referenced line or type. The same guidance addresses terms such as Basic Automobile, Comprehensive Auto, and Stop Gap liability in their respective certificate sections.

Where Argo fits

Argo Insurance can walk through an ACORD certificate line by line against the policy and endorsements behind it, and tell you which boxes are supported, which need a carrier endorsement, and which requests Texas law does not permit on the form at all. That distinction saves the loop of revised certificates that never fixes the underlying issue.

Start with a COI request if the policy is in place, or a contractor certificate review if a general contractor has rejected a document and you need to know why. The same-day certificate guide covers what to send to move a request quickly, and the vendor certificate guide covers procurement onboarding specifically.

Coverage descriptions here are general. Limits, exclusions, endorsements, and eligibility vary by carrier, and the policy issued controls.