CG 20 37: Additional Insured, Owners, Lessees or Contractors, Completed Operations

Why CG 20 37 exists and what it covers

Until 1993, CG 20 10 granted additional insured status for liability arising out of "your work", and that reached completed operations. The 10 93 edition limited CG 20 10 to ongoing operations, which left owners and general contractors without additional insured protection after turnover. ISO released CG 20 37 10 01 so completed operations coverage could be added back by a separate endorsement.

The current grant amends Who Is An Insured to include the scheduled person or organization, but only for "bodily injury" or "property damage" caused, in whole or in part, by "your work" at the location designated and described in the schedule, performed for that additional insured and included in the "products-completed operations hazard". Personal and advertising injury is not part of the grant, and payments under it reduce the policy's products-completed operations aggregate rather than the general aggregate.

Under the CGL coverage form, work is treated as completed at the earliest of three points: when all work called for in the contract is done, when all work at one job site is done on a contract covering several sites, or when part of the work has been put to its intended use by anyone other than another contractor or subcontractor on the same project. That last trigger matters on phased projects where floors or buildings are occupied before the job closes out.

How CG 20 37 decides a completed operations tender

Completed operations claims arrive late. A roof membrane fails in the second winter, a curtain wall anchor corrodes, a balcony guardrail gives way after tenants move in. The claimant sues the owner and the general contractor, and the general contractor tenders to each responsible subcontractor's carrier. Under an occurrence policy, the carrier that receives the tender looks at the policy in force when the injury or damage occurred, not the policy in force when the subcontractor did the work.

That timing rule is the trap. If the subcontractor's renewal two years after closeout dropped CG 20 37, or its schedule no longer reaches your project, the tender fails even though the endorsement was perfect during construction. Contracts therefore require subcontractors to keep completed operations coverage, with the additional insured endorsement, for a set number of years after final completion, often tied to the state's statute of repose.

The gap is common at the first review, before renewals are even in play: 64% of COIs claiming additional insured status fail to attach the CG 20 37 completed operations endorsement (IRMI Construction Risk Survey).

CG 20 37 edition comparison: 10 01, 07 04, 04 13 and 12 19

The 10 01 edition covered liability "arising out of" your work. The 07 04 edition changed that to injury or damage "caused, in whole or in part, by" your work, which removed coverage for the additional insured's sole negligence. The 04 13 edition added the familiar limiters: coverage applies only to the extent permitted by law, it is no broader than the contract requires, and the carrier pays the lesser of the contract requirement or the available limits.

The 12 19 edition keeps the 04 13 structure and rewrites the limits language so it refers to limits available under the applicable limits of insurance rather than limits shown in the Declarations, adding that the endorsement shall not increase the applicable limits. The same 2019 filing introduced CG 20 39 and CG 20 40, automatic completed operations forms that apply when the named insured agreed in a written contract to add the party. CG 20 37 remains the scheduled form, so it does not depend on a written contract to grant status, although its limiters look to the contract whenever one exists.

What to require for completed operations

Require CG 20 37 04 13 or 12 19, or a form at least as broad, naming the same parties as the ongoing operations endorsement. Describe the location as the project address and number, or as all locations where required by written contract if the carrier accepts that description. State the number of years the subcontractor must keep the endorsement in force after final completion, and require a fresh endorsement copy at every renewal during that period.

• Duration: completed operations additional insured coverage maintained for a stated period after final completion, commonly matched to the project state's statute of repose.
• Limits: products-completed operations aggregate of not less than $2,000,000, stated as the additional insured requirement.
• Scope: no residential, condominium or EIFS exclusion for the trade unless the subcontract allows it.
• Evidence: the CG 20 37 page attached to every renewal certificate, not only the first one.

How Pikorua Security verifies CG 20 37 through closeout and beyond

Pikorua Security treats completed operations as its own rule. Rule AI-02 requires a CG 20 37 or approved equivalent whenever the contract exhibit calls for completed operations, checks the edition, and compares the schedule's location and description with the project record pulled from Procore or your ERP. A packet with CG 20 10 and no CG 20 37 is marked Deficient, not Pending.

After substantial completion, the subcontractor moves to a closeout watchlist for as many years as your contract requires. Each renewal runs through the 60, 30, 15 and 0 day cadence, and Pikorua Security asks the broker for the renewal's CG 20 37 page by name. If a renewal drops the endorsement, the subcontractor and broker receive a deficiency notice and retention or final payment can stay on hold until it is fixed.