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COI Compliance Audit Checklist
The 15 things every insurance auditor or owner will check in your subcontractor compliance records.
- 1
Complete subcontractor list
A full list of every sub you worked with during the audit period, with legal name, entity type, EIN, total paid, and projects worked.
- 2
Valid W-9 on file for every sub
W-9 dated before first payment, with legal name, TIN, federal tax classification, and signature.
- 3
Current COI covering work period
For every sub, a Certificate of Insurance that was active during the dates they worked on your project, not just their current COI today.
- 4
GL limits meet contract minimums
Each sub’s General Liability limits equal or exceed the minimums specified in your subcontract.
- 5
Additional Insured endorsements on file
Actual CG 20 10 and CG 20 37 endorsement pages, not just COI references. Required for any sub you claim as AI.
- 6
Primary and Non-Contributory language
CG 20 01 endorsement or PNC language built into the AI endorsement. Required so the sub’s insurance pays first.
- 7
Waiver of Subrogation documentation
CG 24 04 for General Liability and WC 00 03 13 for Workers’ Comp, where required by contract.
- 8
Workers' Comp coverage for every sub with employees
Active WC coverage during the work period, verified via COI or state fund portal in monopolistic states (ND, OH, WA, WY).
- 9
WC exemption certificates for sole proprietors
State-issued exemption certificate on file for any sub claiming exempt status. Not just the sub’s verbal assertion.
- 10
Active contractor license for each trade
State and local licenses where required, verified through state licensing board lookup. Valid during the work period.
- 11
Signed subcontractor agreements for every sub
Executed subcontract specifying insurance, indemnification, and compliance requirements. Every sub you paid should have a signed contract.
- 12
Documented stop-work procedures
Written procedure and audit trail showing how you handle expired documentation and enforce compliance across projects.
- 13
Payroll separation between subs and employees
Clear records distinguishing 1099 contractors from W-2 employees. Subs should have contracts, COIs, W-9s, and business entities.
- 14
Record retention for full audit period
Organized, retrievable records for the statute of limitations applicable to your jurisdiction (typically 3-10 years for construction).
- 15
Searchable, organized compliance system
A searchable record system (not a three-ring binder) showing every sub, every document, every expiration, every project.
Walk into your next audit prepared
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