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Legal & Risk Transfer

The CG 20 10 Trap: Why Ongoing Operations Leaves You Exposed to Completed Claims

Most subcontractor certificates say "additional insured" and stop there. If the endorsement behind that line is a modern CG 20 10 with no CG 20 37 beside it, your protection ends the day the sub's work is finished.

Kavya Reddy, ARM, CRISHead of Risk Engineering
Published
Reading time
6 minutes
In this article
  1. What CG 20 10 actually covers
  2. How the edition dates changed the deal
  3. Why the causation wording matters as much as the date
  4. Where completed operations claims come from
  5. The fix: require both forms, and say for how long
  6. What to check at intake

What CG 20 10 actually covers

CG 20 10 is the ISO endorsement titled Additional Insured, Owners, Lessees or Contractors, Scheduled Person or Organization. It adds the party named in its schedule as an insured on the subcontractor's commercial general liability policy. It does not hand that party the whole policy. It grants coverage for a defined slice of liability, and since the 10 93 edition that slice has been tied to the named insured's "ongoing operations" performed for the additional insured.

Ongoing is the word that matters. The endorsement responds while the subcontractor's crew is on site doing the work. Later editions spell out the boundary with an express exclusion: no coverage for bodily injury or property damage that occurs after all work on the project is complete, or after the portion of the work that caused the loss has been put to its intended use by anyone other than another contractor working on the same project.

For a general contractor, that is a narrow window. The expensive construction claims are rarely the ones that happen while the scaffold is up. They are water intrusion, cracked slabs and failed connections that surface months or years after turnover, when the only part of the subcontractor's policy still in play is the products-completed operations hazard.

How the edition dates changed the deal

The edition date printed in the footer of the form tells you which deal you actually got. Six editions come up again and again in contract exhibits and coverage disputes, and each one moved the line between what the additional insured gets and what it does not:

  • 11 85: covered liability arising out of "your work" for the additional insured, which courts have generally read to include completed operations. Some contracts still demand this edition by name, and few carriers will issue it.
  • 10 93: narrowed the grant to "your ongoing operations". Completed operations status for the additional insured disappeared from the standard form.
  • 10 01: ISO introduced CG 20 37, Additional Insured, Owners, Lessees or Contractors, Completed Operations, as the separate endorsement that restores completed operations status.
  • 07 04: replaced "arising out of" with "caused, in whole or in part, by" the named insured's acts or omissions, removing coverage for the additional insured's sole negligence.
  • 04 13: added "only to the extent permitted by law", limited coverage to what the written contract requires, and capped the limits at the lesser of the contract requirement or the policy limits.
  • 12 19: removed the reference to limits "shown in the Declarations" and states that the endorsement does not increase the applicable limits, which matters when a per-project aggregate endorsement such as CG 25 03 sits on the policy.

Why the causation wording matters as much as the date

The 07 04 editions replaced "arising out of" with "caused, in whole or in part, by" the named insured's acts or omissions. The phrase sounds generous. Courts have not always read it that way. In Burlington Insurance Co. v. NYC Transit Authority (2017), New York's Court of Appeals held that the language reaches only injury proximately caused by the named insured, not every injury with a but-for connection to the subcontractor's work.

The practical effect is that the general contractor is covered when the subcontractor's negligence is at least a proximate cause of the loss. If the facts point to the general contractor alone, the additional insured grant may not respond at all. Early in a case, before fault is sorted out, carriers often accept the defense under a reservation of rights on exactly this point.

So the edition date and the causation wording both belong in your review. A certificate remark that reads "CG 20 10 per written contract" tells you neither.

Where completed operations claims come from

Consider Ridgeline Roofing Inc., which finishes a membrane roof on a four-story medical office building in May. The following February a seam opens during a freeze-thaw cycle, water runs through two floors of tenant improvements, and the owner sues the general contractor for property damage and lost rent. The general contractor tenders to Ridgeline's carrier. The carrier pulls the endorsement on file: CG 20 10 04 13, with no CG 20 37 behind it. Ridgeline's work was complete and in use. The tender is denied.

The general contractor's own policy now responds, after its self-insured retention. For contractors with $25 million to $100 million in revenue that retention typically runs $50,000 to $250,000, and the average out-of-pocket litigation and retention loss when an additional insured tender is denied runs $150,000 to $450,000 (Commercial Casualty Actuarial Study).

This is not an edge case. The IRMI Construction Risk Survey found that 64% of initial certificates claiming additional insured status fail to attach CG 20 37. In Pikorua Security's 2026 benchmark, roofing carried the highest defect rate of any trade, at 84%.

The fix: require both forms, and say for how long

The contract is where this gets solved. An insurance exhibit that simply says "name Contractor as additional insured" invites the narrowest endorsement the subcontractor's carrier offers. Effective exhibits require additional insured status for both ongoing and completed operations and name the forms or their equivalents: CG 20 10 with CG 20 37, or blanket wording such as CG 20 38 for ongoing operations paired with CG 20 39 or CG 20 40, the automatic completed operations forms ISO introduced with its 2019 filings.

Exhibits should also state how long completed operations status must be maintained after the work is finished. Many contracts tie that period to the statute of repose in the project's state, which varies, so it is a decision for your construction counsel rather than a default to copy. Counsel should draft the insurance exhibit and the indemnity clause together, because the two need to describe the same obligation.

Finally, require copies of the endorsements themselves. A certificate is a summary written by the broker. The endorsement is the coverage.

What to check at intake

Pikorua Security's Endorsement Validator reads the edition date from the footer of each endorsement page and flags a CG 20 10 without a matching CG 20 37 in about 15 seconds, with 99.4% verification accuracy across ISO forms. Whatever tool you use, the review starts where the certificate ends.

For every additional insured packet, the intake check comes down to five questions:

  • Are both endorsements attached: CG 20 10 and CG 20 37, or blanket forms that cover ongoing and completed operations?
  • Is the edition date in each form footer one the contract accepts?
  • Does the schedule name your legal entity, or is the blanket wording triggered by a written contract you actually signed with this subcontractor?
  • Does the products-completed operations aggregate on the ACORD 25 meet the contract, and is it free of exclusions?
  • Is the forms schedule free of limiting endorsements that hollow out the grant, such as CG 21 39 or a designated work exclusion covering your project type?

About the author

Kavya Reddy, ARM, CRIS

Head of Risk Engineering, Pikorua Security

Kavya leads Pikorua Security's risk engineering team, which writes the contract rules and endorsement checks behind the product. She spent 11 years in US construction risk transfer before joining Pikorua Security and holds the ARM and CRIS designations.

The Risk Transfer Brief explains insurance and contract concepts in general terms. Pikorua Security is software, not a law firm, insurer or broker. For contract drafting, or a coverage position on a specific claim, work with your coverage counsel.

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