Description of Operations: Where COI Compliance Really Lives

Most people reviewing a Certificate of Insurance spend their time on the coverage grid — checking limit amounts, verifying policy numbers, confirming expiration dates. Then they glance at the Description of Operations box at the bottom of the ACORD 25, see a block of dense text, and move on.

This is a critical mistake. The Description of Operations box is where COI compliance actually lives. It is the only place on the certificate where Additional Insured status, Waiver of Subrogation, Primary and Noncontributory language, project references, and endorsement form numbers are documented. The coverage grid tells you the vendor has insurance. The Description of Operations tells you whether that insurance protects you.

What the Description of Operations Box Is

The Description of Operations / Locations / Vehicles section occupies the lower portion of the ACORD 25 certificate, below the coverage grid and above the Certificate Holder information. It is a free-text field where the insurance producer (broker or agent) describes the nature of the insured's operations and documents any special provisions that apply.

ACORD's official guidance states this section should describe "those operations of the named insured for which the certificate is being issued and any special provisions." In practice, it serves as the only place to communicate endorsement-level details on a certificate that is otherwise limited to checkboxes and numeric fields.

The box has a character limit, and producers often compress language to fit. This creates dense, abbreviated text that requires careful reading.

What You Should Find in the Description

A properly completed Description of Operations box for a vendor working on your property or project should contain several specific elements.

Additional Insured Language

The most important item. If your organization is required to be an Additional Insured on the vendor's policies, this must be stated in the Description of Operations. Look for language such as:

"[Your Organization Name] is included as Additional Insured with respect to General Liability as required by written contract per CG 20 10 and CG 20 37."

Key elements to verify:

• Your organization's name appears correctly — not abbreviated, not misspelled, not a different entity in your corporate family
• The coverage type is specified (General Liability, Auto, Umbrella)
• Endorsement form numbers are referenced (CG 20 10 for ongoing operations, CG 20 37 for completed operations)
• The trigger language indicates the basis — "as required by written contract" for blanket endorsements, or your specific name for scheduled endorsements

The Additional Insured checkbox in the coverage grid is a useful indicator, but the Description of Operations is where the details live. A checked box without corresponding language in the Description is incomplete verification.

Waiver of Subrogation Language

If your requirements include Waiver of Subrogation, the Description should state it explicitly:

"Waiver of Subrogation applies in favor of [Your Organization Name] with respect to General Liability (CG 24 04), Workers' Compensation (WC 00 03 13), and Commercial Auto (CA 04 44) as required by written contract."

Again, the key elements are the provision name, the coverage types it applies to, the endorsement form numbers, and the identification of the beneficiary (your organization or blanket language).

Primary and Noncontributory Language

This provision ensures the vendor's policy pays first and does not seek contribution from your own insurance. In the Description, it appears as:

"General Liability coverage is Primary and Noncontributory as required by written contract per CG 20 01 04 13."

The endorsement form CG 20 01 (Primary and Noncontributory — Other Insurance Condition) is the ISO form that modifies the "other insurance" clause in the vendor's CGL policy.

Project or Location References

For project-specific requirements, the Description should identify the applicable project, location, or contract:

"Re: 450 Park Avenue, New York, NY — Lobby Renovation Project, Contract #2026-0147"

This reference ties the certificate to a specific engagement. Without it, the certificate is general — it covers whatever the vendor does, wherever they do it. With a project reference, it confirms that the provisions apply specifically to your project.

What "As Required by Written Contract" Means

This phrase appears in virtually every Description of Operations for vendors with blanket endorsements, and it is the most misunderstood language on the certificate.

"As required by written contract" means the endorsement on the vendor's policy is a blanket endorsement that automatically applies to any party the vendor is contractually obligated to include. The endorsement does not name you specifically. Instead, it says (paraphrasing): "Any person or organization that the Named Insured is required by written contract to include as an Additional Insured / provide a Waiver of Subrogation for / make coverage Primary and Noncontributory is automatically covered."

For this language to protect you, two conditions must be met:

1. A written contract exists between your organization and the vendor.
2. That contract requires the specific provision (Additional Insured, Waiver of Subrogation, Primary and Noncontributory).

If your contract is silent on insurance requirements, or if you have no written contract at all, the blanket endorsement does not apply to you — even though the certificate says it does. The certificate itself does not create contractual obligations. It merely reports what the policy endorsements provide.

This is why the insurance requirements in your vendor agreement are just as important as the certificate itself. The contract creates the obligation. The endorsement fulfills it. The certificate documents it.

Endorsement Form Numbers: Why They Matter

Experienced compliance reviewers look for specific endorsement form numbers in the Description of Operations. These numbers reference standardized ISO (Insurance Services Office) endorsement forms that have defined, known coverage terms.

Common GL Endorsement Forms

• CG 20 10 — Additional Insured, Ongoing Operations. Provides AI status for claims arising from the vendor's current work.
• CG 20 37 — Additional Insured, Completed Operations. Extends AI status to claims arising after the vendor's work is finished.
• CG 20 26 — Additional Insured, Designated Person or Organization. A broad form that covers both ongoing and completed operations (depending on edition date).
• CG 24 04 — Waiver of Transfer of Rights of Recovery Against Others (Waiver of Subrogation for GL).
• CG 20 01 — Primary and Noncontributory endorsement.
• CG 25 03 / CG 25 04 — Designated Construction Project(s) General Aggregate Limit (per-project aggregate).

Common WC Endorsement Forms

• WC 00 03 13 — Waiver of Our Right to Recover From Others (Waiver of Subrogation for Workers' Comp).

Common Auto Endorsement Forms

• CA 20 48 — Designated Insured (Additional Insured for auto).
• CA 04 44 — Waiver of Transfer of Rights of Recovery Against Others (Waiver of Subrogation for auto).

When these form numbers appear in the Description, they provide a higher level of assurance that the actual endorsement exists on the policy. A Description that says "Additional Insured per CG 20 10 and CG 20 37" is more reliable than one that simply says "Additional Insured."

However, form numbers alone are not absolute proof. The certificate is an informational document, not a contract. The actual endorsement on the actual policy is the definitive source. But form numbers in the Description are the best verification available on a certificate.

Red Flags to Watch For

No Description of Operations Text at All

A blank or near-blank Description ("General contracting operations") means no provisions have been documented. If your requirements include Additional Insured, Waiver of Subrogation, or Primary and Noncontributory, a blank Description is non-compliant regardless of what the checkboxes in the coverage grid indicate.

Boilerplate Without Specifics

"Certificate Holder is Additional Insured." This is better than nothing but lacks endorsement form numbers, coverage type specification, and does not address ongoing vs. completed operations. It raises questions about whether the endorsement actually exists or the producer simply typed a generic statement.

Mismatched Names

The organization name in the Description does not match the Certificate Holder name, or it names a parent company when the subsidiary is the contracting entity. Additional Insured status is entity-specific. Coverage for "ABC Holdings LLC" does not automatically extend to "ABC Property Management Inc."

"For Informational Purposes Only" Language

Some certificates include language in or near the Description stating that the certificate is issued "for informational purposes only" and "confers no rights upon the certificate holder." While this language is technically accurate (a certificate is not a contract), its presence sometimes indicates that the producer is being cautious about what they are willing to confirm. Investigate further.

Missing Completed Operations

The Description references CG 20 10 (ongoing operations) but not CG 20 37 (completed operations). This means your Additional Insured coverage ends when the vendor finishes their work — precisely when long-tail claims (construction defects, latent damage) begin to emerge.

Restrictive Language

"Additional Insured status applies only to claims arising from the Named Insured's sole negligence." This restriction significantly narrows the protection. Most claims involve shared responsibility. If the endorsement only covers the vendor's sole negligence, it may not respond to the most common claim scenarios.

How AI Changes Description of Operations Review

Manual review of the Description of Operations is time-consuming and error-prone. The text is dense, abbreviations vary by producer, and the relevant language is often buried in the middle of a paragraph. A human reviewer scanning 50 certificates per day will inevitably miss something.

AI-powered certificate review systems parse the Description of Operations text, extract specific provisions, match them against your requirements, and flag discrepancies. The system identifies whether Additional Insured, Waiver of Subrogation, and Primary and Noncontributory language is present, which coverage types it applies to, whether endorsement form numbers are referenced, and whether the certificate holder name matches.

This is not about replacing human judgment — it is about ensuring that no provision is overlooked due to fatigue, volume, or the difficulty of reading compressed text in a small box on a PDF.