ACORD 25 vs ACORD 28: Which Certificate Do You Need?
Inori Team
COI Compliance Experts
If you work in insurance compliance, you have likely encountered both the ACORD 25 and the ACORD 28. They are both certificate forms issued by insurance producers, they both provide evidence of coverage, and they both follow the ACORD standard format. But they serve fundamentally different purposes and cover different types of insurance.
Understanding when you need each form — and what to look for on each — is essential for a complete compliance program.
The Core Difference
The distinction is straightforward:
- ACORD 25 — Certificate of Liability Insurance
- ACORD 28 — Evidence of Property Insurance (also called Evidence of Commercial Property Insurance)
The ACORD 25 proves that a business has liability coverages: General Liability, Automobile Liability, Umbrella/Excess Liability, and Workers' Compensation. These coverages protect against claims made by third parties for bodily injury, property damage, and related losses caused by the insured's operations.
The ACORD 28 proves that a business has property insurance: coverage for physical assets like buildings, equipment, inventory, and tenant improvements. This coverage protects the insured's own property (and in some cases, the property of others in the insured's care) against perils like fire, theft, wind, and water damage.
In short: the ACORD 25 is about liability to others. The ACORD 28 is about protecting physical assets.
When You Need the ACORD 25
The ACORD 25 is required in virtually every business relationship where one party could cause harm to another. The most common scenarios:
Hiring contractors or subcontractors. Before a contractor sets foot on your property, you need proof that they carry General Liability and Workers' Compensation. If their employee is injured or they damage your property, their insurance — not yours — should respond.
Onboarding vendors. Whether it is a janitorial service, an IT provider, or a catering company, any vendor performing work on your behalf should provide an ACORD 25 showing adequate liability coverage.
Commercial leases. Landlords require tenants to carry General Liability insurance and typically require Additional Insured status. The ACORD 25 is the standard proof.
Vehicle operations. If a vendor uses vehicles in the course of their work for you, the Automobile Liability section of the ACORD 25 confirms they carry auto insurance.
When You Need the ACORD 28
The ACORD 28 is required whenever you need proof that physical property is insured. Common scenarios include:
Commercial leases (landlord perspective). If you are a landlord and your tenant has made improvements to their space (tenant build-outs, fixtures, equipment), you may require an ACORD 28 proving the tenant insures those improvements. If the tenant's build-out is destroyed by fire and they have no property insurance, you could face a dispute about who is responsible for restoration.
Lender requirements. Banks and lenders that finance commercial property require evidence that the property is insured. The ACORD 28 provides this proof. Without it, the lender may force-place insurance at a significantly higher premium.
Bailment situations. If you entrust your property to another party — equipment sent for repair, inventory stored in a third-party warehouse — the ACORD 28 can prove that the bailee has property insurance covering your goods.
Landlord proof to tenants or investors. Some tenants and investors want to see evidence that the building itself is insured. The landlord provides an ACORD 28 showing the building's property coverage.
What Each Form Contains
ACORD 25 Coverage Sections
| Section | What It Covers |
|---|---|
| Commercial General Liability | Third-party bodily injury and property damage, personal/advertising injury |
| Automobile Liability | Bodily injury and property damage from vehicle operations |
| Umbrella/Excess Liability | Additional limits above underlying liability policies |
| Workers' Compensation | Employee injuries and occupational disease, employers' liability |
Additional fields include policy numbers, effective/expiration dates, coverage limits, insurer names with NAIC numbers, the Description of Operations (where endorsement language appears), and the Certificate Holder section.
ACORD 28 Coverage Sections
| Section | What It Covers |
|---|---|
| Property Coverage | Building, contents, business personal property |
| Covered Perils | Named perils, broad form, special (all-risk) form |
| Valuation | Replacement cost vs. actual cash value |
| Coinsurance | The percentage of value the insured must maintain |
| Deductible | The amount the insured pays before insurance responds |
| Mortgage/Loss Payee | Parties with a financial interest in the property |
The ACORD 28 also includes fields for the property location, the building description, and the specific property items being insured. It can show whether flood insurance or earthquake coverage is in place, which are typically written as separate policies.
Key Differences at a Glance
| Feature | ACORD 25 | ACORD 28 |
|---|---|---|
| Full title | Certificate of Liability Insurance | Evidence of Commercial Property Insurance |
| Coverage focus | Liability to third parties | Physical property/assets |
| Common coverages | CGL, Auto, Umbrella, Workers' Comp | Building, contents, business personal property |
| Key limits | Per occurrence, aggregate, CSL | Property value, deductible, coinsurance |
| Endorsement language | Additional Insured, Waiver of Subrogation | Loss Payee, Mortgage Holder |
| Typical requestor | Property manager, GC, landlord | Lender, landlord, property owner |
| Trigger | Third-party claims | Physical loss or damage to property |
Can You Need Both?
Yes, and it is common. Consider a commercial tenant:
- The landlord requires an ACORD 25 from the tenant to prove General Liability coverage (protecting the landlord if a tenant's customer is injured) and may require the tenant to name the landlord as Additional Insured.
- The landlord also requires an ACORD 28 from the tenant if the tenant has significant build-outs or inventory, proving the tenant insures their own property and will not look to the landlord if those assets are damaged.
- Conversely, the tenant might request an ACORD 28 from the landlord to confirm the building itself is insured.
In construction, a general contractor typically requires ACORD 25 certificates from all subcontractors (liability coverage) and may also require an ACORD 28 from a subcontractor if the sub has expensive equipment on site.
The ACORD 27: The Residential Equivalent
For completeness, the ACORD 27 (Evidence of Property Insurance) is similar to the ACORD 28 but is used for homeowners and dwelling policies rather than commercial property. If you work in residential real estate or residential mortgage lending, you encounter the ACORD 27 instead of the ACORD 28.
Common Mistakes
Mistake 1: Requesting Only the ACORD 25
Many compliance programs focus exclusively on liability coverage and neglect property insurance verification. If your contracts include property-related requirements — such as requiring tenants to insure their build-outs — you need the ACORD 28 as well.
Mistake 2: Confusing Coverage Types
Occasionally, a reviewer sees "property damage" in the General Liability section of an ACORD 25 and assumes it means the vendor has property insurance. It does not. The "property damage" limit on a CGL policy covers damage the insured causes to someone else's property. It does not cover damage to the insured's own property.
Mistake 3: Ignoring Valuation Method
On the ACORD 28, the valuation method matters. Replacement cost means the insurer will pay to replace the property with like kind and quality, without deduction for depreciation. Actual cash value (ACV) means the insurer deducts depreciation. If a tenant has a $500,000 build-out that is five years old and their policy is ACV, the payout after a total loss might only be $300,000. For high-value improvements, require replacement cost valuation.
Mistake 4: Not Checking the Loss Payee
On the ACORD 28, the loss payee is the party that receives insurance proceeds if a loss occurs. If you are a landlord and the tenant's improvements were partially financed by you, you may need to be listed as a loss payee. Similarly, lenders require loss payee status to protect their collateral.
Building a Complete Compliance Program
A comprehensive compliance program requires both liability and property verification:
- Define requirements for both liability (ACORD 25) and property (ACORD 28) coverage based on your contracts and risk profile
- Collect both forms from applicable vendors, tenants, and partners
- Verify both forms against your specific requirements
- Track expirations for both liability and property policies — they often have different renewal dates
- Automate wherever possible, since managing two certificate types per vendor doubles the compliance workload
Verify ACORD 25 and ACORD 28 forms automatically
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Summary
The ACORD 25 and ACORD 28 are complementary forms that serve different purposes. The ACORD 25 proves liability coverage — protection against claims from third parties. The ACORD 28 proves property coverage — protection for physical assets. Most compliance programs need both, and understanding the distinction ensures you are collecting the right evidence for the right risks.
Do not assume that one form covers everything. Know which form you need, know what to verify on each, and make both part of your standard compliance workflow.
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