Description of Operations
Free-text ACORD 25 section documenting additional insured status, waiver of subrogation, primary/non-contributory language, and endorsement forms — the most important narrative field on a COI.
Overview
The Description of Operations / Locations / Vehicles section — typically abbreviated DoO — is a multi-line free-text box on the ACORD 25 that sits below the coverage grid. It is where a producer documents everything that does not fit into the form's structured fields: additional insured status, waiver of subrogation language, primary non-contributory wording, endorsement form numbers (CG 20 10, CG 20 37, CG 24 04, etc.), project-specific language, and other contractual provisions.
Because most coverage modifications happen by endorsement, not by checking a box, the DoO is often the only place where critical coverage provisions are actually visible on the COI. The checkboxes above the grid (ADDL INSD, SUBR WVD) merely confirm the existence of an endorsement — the DoO is where the language describing who and how lives.
How It Works
A typical DoO on a commercial contractor's COI might read:
"RE: 123 Main Street construction project. Client Corp and its subsidiaries, officers, directors, and employees are named as Additional Insureds on the General Liability policy per CG 20 10 (ongoing) and CG 20 37 (completed operations). Waiver of Subrogation applies per CG 24 04 in favor of Client Corp. Coverage is primary and non-contributory."
Each phrase is technical:
- "Named as Additional Insureds" — confirms AI status exists.
- "per CG 20 10 and CG 20 37" — identifies the exact ISO endorsement forms, so the reviewer can verify the granted scope (ongoing vs. completed operations).
- "Waiver of Subrogation... per CG 24 04" — names the form granting the waiver.
- "Primary and non-contributory" — confirms that the policy will respond before the certificate holder's own policy and without seeking contribution.
Missing or vague DoO language is a persistent source of coverage disputes. A COI stating only "ABC Corp is additional insured" without form numbers provides no way to verify scope — the AI endorsement might be limited to ongoing operations only, silent on completed operations, or restricted to a single location.
Common DoO Patterns
| Phrase | Meaning |
|---|---|
| "Additional Insured per CG 20 10" | AI for ongoing operations only |
| "Additional Insured per CG 20 10 and CG 20 37" | AI for ongoing + completed operations |
| "Additional Insured on a blanket basis as required by written contract" | Blanket AI via endorsement (no scheduled list needed) |
| "Waiver of Subrogation per CG 24 04" | Blanket waiver endorsement |
| "Primary and non-contributory" | Coverage order: this policy pays first |
| "RE: [project name/number]" | Scopes the certificate to a specific job |
On the COI / Where it appears on ACORD 25
The DoO is the large rectangular box labeled DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES, located between the coverage grid and the Certificate Holder block. The ACORD 25 (2016/03 revision) provides approximately 10 lines of typed text; overflow is typically routed to an attached ACORD 101 (Additional Remarks Schedule).
A blank DoO on a COI issued for a contract-heavy vendor relationship is itself a warning sign — the certificate likely does not document the coverages the contract requires.
Why It Matters for Compliance
- Endorsement verification: Inori's extraction captures
description_of_operationsas a free-text field and parses it for referenced endorsement form numbers (CG 20 10, CG 20 37, CG 24 04, etc.), storing them inprovisions.endorsement_forms_mentioned. - Provision detection: The guard specifically scans the DoO for
waiver_of_subrogation_mentioned,primary_noncontributory_mentioned, andadditional_insured_entitiesarrays — each surfaces in the compliance report. - Contract-match diagnostics: When a contract requires "Primary and Non-Contributory per CG 20 01" and the DoO is silent on P&NC language, Inori flags a coverage gap even if the ADDL INSD checkbox is marked.
- Overflow awareness: Inori's multi-form extraction detects ACORD 101 attachments and concatenates their content into the DoO field so downstream compliance checks see the full narrative.
Related Concepts
The DoO is the home for Additional Insured and Waiver of Subrogation language, and is where Primary Non-Contributory wording must appear. It references Endorsement form numbers that modify the underlying policy and is a critical narrative complement to the structured data on the Certificate of Insurance.
See how Inori handles description of operations
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