ACORD 25 vs ACORD 28: Key Differences Every Risk Manager Should Know

ACORD forms are the universal language of insurance documentation. The Association for Cooperative Operations Research and Development - better known as ACORD - publishes standardized forms that insurers, brokers, and certificate holders use to communicate coverage information. Two forms dominate the world of commercial insurance verification: ACORD 25 and ACORD 28. Together they cover more than 80% of all certificate requests you'll encounter in property management, construction, staffing, and commercial lending.

But they are fundamentally different documents covering entirely different types of risk. Requesting the wrong form, misreading the one you received, or failing to understand what each form legally represents can create serious compliance gaps. This guide breaks down everything a risk manager, property manager, or general contractor needs to know about both forms - what they cover, what they don't, how to read each one, and how to process both at scale.

What Is ACORD 25?

The ACORD 25 is the Certificate of Liability Insurance. It is the most commonly requested insurance document in commercial transactions and the form most people mean when they say "COI." When a general contractor asks a subcontractor for their insurance, they want an ACORD 25. When a property manager asks a vendor for proof of insurance before allowing work in a building, they want an ACORD 25. When a staffing agency's client requires evidence of workers compensation coverage, they want an ACORD 25.

The ACORD 25 is a one-page summary document - technically a "certificate of insurance," which is a standardized evidence of coverage issued by the insured's broker or insurance company. It is not the policy itself, and this distinction matters enormously in coverage disputes (more on that below).

What Coverage Types Appear on ACORD 25

A standard ACORD 25 has dedicated sections for:

• Commercial General Liability (CGL) - covers bodily injury and property damage arising from the insured's operations, products, and completed work. The two key limits are per-occurrence (the max payout per individual claim) and general aggregate (the max payout across all claims in a policy year).
• Automobile Liability - covers vehicles used in business operations. The form specifies the covered autos description (Any Auto, All Owned Autos, Scheduled Autos, Hired Autos, Non-Owned Autos) and the combined single limit.
• Umbrella / Excess Liability - sits above the primary GL and auto policies, extending coverage once primary limits are exhausted. The certificate shows whether it's occurrence or claims-made, and the each-occurrence and aggregate limits.
• Workers Compensation and Employer's Liability - WC covers medical and disability benefits for injured workers as required by state law; employer's liability covers the employer's tort exposure above the WC statutory benefits.
• Other coverage types - the form has a catch-all section for professional liability, cyber liability, inland marine, or other lines the broker wants to disclose.

Key Fields on ACORD 25 That Drive Compliance

The Named Insured field identifies the policyholder - the entity that purchased the insurance. This must match the legal entity name of the subcontractor or vendor you're hiring.

The Certificate Holder field identifies who the certificate is being issued to - typically your organization. This field matters because some policies have blanket additional insured language that only activates when you're named in the certificate holder box.

The Description of Operations box is where additional insured status, waiver of subrogation, and project-specific notes are disclosed. This is a free-text field, and the language here varies widely between brokers. Some will list endorsement numbers; others write narrative descriptions.

The Additional Insured and Subrogation Waived checkboxes are present on ACORD 25 (2016 version and later). These are helpful quick indicators but are not legally binding - only the underlying policy endorsements create coverage.

What Is ACORD 28?

The ACORD 28 is the Evidence of Commercial Property Insurance. This is a fundamentally different document from ACORD 25 in both its legal function and its practical use cases. The critical distinction is in the name: it is evidence of property coverage, not a certificate.

While an ACORD 25 is issued to a certificate holder who has an insurable interest in the named insured's liability, an ACORD 28 is issued to an interested party - typically a lender, lessor, or mortgagee - who wants assurance that the property they have an interest in is insured. The ACORD 28 does not confer rights to the interested party the way additional insured status on an ACORD 25 does. It is informational evidence, not a transfer of policy rights.

What Coverage Types Appear on ACORD 28

The ACORD 28 focuses entirely on property-side coverage:

• Building - the structure itself, valued on a replacement cost or actual cash value basis. The form shows the coverage limit and the basis of valuation.
• Business Personal Property (BPP) - furniture, equipment, inventory, and other contents belonging to the insured within the insured premises.
• Business Income / Extra Expense - covers lost revenue and additional costs incurred when a covered property loss forces a business interruption. The form shows the coverage period and limit.
• Electronic Data Processing (EDP) - covers computer hardware, software, and data when separately scheduled from the BPP.
• Crime - employee dishonesty, forgery, theft, and other crime coverages.
• Inland Marine - covers mobile property in transit or stored away from the insured premises, including contractor's equipment and installation floaters.
• Other - a catch-all for specialized property coverages.

The Property Location Section

ACORD 28 includes a property location schedule that lists each covered location with its address and the applicable coverage limits. This is critical for lenders: a bank with a mortgage on a specific building needs to verify that building's address appears in the covered locations with adequate limits - not just that the insured has some property coverage somewhere.

Mortgagees and loss payees are listed separately on ACORD 28. A mortgagee is typically a lender with a security interest in the property - they have a priority claim to insurance proceeds up to their outstanding loan balance. A loss payee has an insurable interest in specific personal property - they receive insurance proceeds for that property if it's destroyed. These are two distinct legal relationships, and the form records them separately.

Side-by-Side Comparison

Which Form Should You Request?

The answer depends entirely on what risk you're trying to verify coverage for.

Request ACORD 25 When:

• You are hiring a contractor, subcontractor, or vendor to perform services
• You want to verify the other party's liability exposure won't become your problem
• Your contract requires the other party to name you as additional insured
• You are onboarding a staffing agency and need to verify WC coverage for placed workers
• You are a tenant in a commercial building and your lease requires liability COI from service providers
• You are a property manager requiring vendors to carry GL before accessing the property

Request ACORD 28 When:

• You are a lender and need to verify the borrower's property is insured to the loan value
• You are a commercial landlord and the lease requires the tenant to insure tenant improvements
• You are financing equipment and need to verify the borrower carries adequate property coverage on the collateral
• You are a SBA lender or bank processing a commercial real estate loan and need evidence of hazard insurance
• You need to verify business income coverage is in place as a condition of a lease or financing agreement

Sometimes You Need Both

The clearest example is a commercial tenant scenario. If you're a commercial landlord with a tenant who runs a business out of your space, you may need:

• ACORD 25 to verify the tenant's GL policy names you as additional insured (so you're protected if a customer slips and falls in their space and sues you as the building owner)
• ACORD 28 to verify the tenant's property coverage includes tenant improvements and betterments at your location (so if a fire damages the build-out you paid for, you have evidence of coverage)

Similarly, a bank financing a commercial construction project may require both: ACORD 28 to evidence builders risk coverage on the structure during construction, and ACORD 25 to verify the GC's liability insurance names the bank as an additional insured in certain loan agreements.

Common ACORD 25 Field Breakdowns - What to Verify

Reading an ACORD 25 looks simple but hides significant complexity. Here's a section-by-section breakdown of what you're actually looking at and what to verify.

Producer Box

The producer is the insurance broker who issued the certificate - not the insurance company. This is who you call if you need to verify coverage or request corrections. Note the producer's contact information - if you find a discrepancy, you need to work through them to get an amended certificate.

Insurer Columns A Through F

Each insurer is listed by NAIC number in addition to their name. The NAIC number is a unique identifier for insurance carriers - use it to verify the carrier is licensed in the state where work is being performed via your state's Department of Insurance website. An unlicensed carrier offering coverage in a state where they're not admitted creates collection risk if a claim is denied.

Also check the carrier's AM Best financial strength rating. A carrier rated B++ or lower is a red flag for large commercial projects. Most owner-mandated specifications require A-rated or better carriers.

General Liability Section

The GL section shows policy number, effective and expiration dates, and up to six limit types: Each Occurrence, Damage to Rented Premises, Medical Expense, Personal and Advertising Injury, General Aggregate, and Products-Completed Operations Aggregate. The General Aggregate is the most commonly confused limit - it is the maximum the carrier will pay across all claims in the policy year combined, not a per-project limit unless the policy includes a per-project aggregate endorsement (look for this on large construction projects; it's worth requiring).

Auto Liability Section

The "Covered Autos" checkboxes are critical. The options in ACORD 25 (2016 version) map to ISO symbols: 1 = Any Auto, 2 = All Owned Autos, 3 = Owned Private Passenger, 4 = Owned Autos Other Than Private Passenger, 5 = Owned Autos Subject to No-Fault, 6 = Owned Autos Subject to Compulsory UM, 7 = Specifically Described Autos (scheduled), 8 = Hired Autos Only, 9 = Non-Owned Autos Only. For most vendor and contractor requirements, you want Symbol 1 (Any Auto) checked.

Description of Operations Box

This is where the most important coverage qualifications are disclosed. Look for: (1) additional insured language and endorsement numbers, (2) waiver of subrogation confirmation and endorsement numbers, (3) project-specific references confirming the certificate applies to your contract, (4) per-project aggregate endorsement if applicable, and (5) primary and non-contributory language if your contract requires it. "Primary and non-contributory" means the sub's policy pays first, and the sub's insurer cannot demand contribution from your policy even if you share additional insured status. This language is standard on most commercial subcontracts and protects your policy limits.

Common ACORD 28 Field Breakdowns - What to Verify

The ACORD 28 is less frequently encountered but equally important to understand when it's required.

Property Description and Locations

The form includes a schedule of covered locations. Verify that the specific property address you care about is listed. "Blanket" coverage on ACORD 28 means all locations are covered under one combined limit rather than each location having its own sublimit - this is usually fine but requires verifying the blanket limit is adequate for your specific property's value.

Coverage Limits and Basis of Valuation

For building coverage, the basis of valuation matters as much as the limit. Replacement Cost Value (RCV) pays to repair or replace the building with new materials at current prices. Actual Cash Value (ACV) deducts depreciation - a 20-year-old roof gets paid out at ACV, which may be a fraction of the replacement cost. Lenders almost always require RCV; verify this explicitly.

The coverage limit should meet or exceed the property's replacement cost. Coinsurance clauses - where the insured must carry coverage equal to a specified percentage (usually 80% or 90%) of the property's full value or face a penalty at claim time - are common in commercial property. If the insured is underinsured relative to the coinsurance requirement, the claim payout is proportionally reduced. Lenders need to be aware of this.

Mortgagee and Loss Payee Listings

Your institution's full legal name and address must appear exactly as it appears on the mortgage documents. A misspelled name or wrong address creates claims processing delays. The ACORD 28 is the document your claims team references when a loss is reported - errors here translate directly into payment delays.

Deductibles

ACORD 28 shows the policy deductible. For lenders, a high deductible (say, $100K on a $2M property) means the borrower is effectively self-insuring the first $100K of any loss. If the borrower doesn't have liquidity to cover the deductible, the property repair could stall. Some loan documents cap the allowable deductible - verify the deductible on ACORD 28 against your loan covenant requirements.

How to Parse Both Forms Automatically

Processing ACORD 25 and ACORD 28 forms at scale presents real technical challenges. These are PDF documents - some computer-generated, some scanned from fax machines, some photographed with phones. Field positions shift between form versions (ACORD 25 has had versions in 2001, 2009, 2010, 2014, and 2016; ACORD 28 similarly). Scanned documents introduce OCR noise. Handwritten entries in some fields break pattern-matching approaches.

The OCR and Layout Challenge

A naive OCR approach reads text from a PDF but loses positional context. Knowing that the text "$1,000,000" appears on the page tells you nothing without knowing whether it's in the Per Occurrence box or the General Aggregate box. Effective COI parsing requires understanding the spatial layout of the form - which region each field occupies - and mapping extracted text to named fields based on position, not just content.

Form version detection matters too. An ACORD 25 from 2009 has different field positions than a 2016 version. A system that's trained on the 2016 layout will misparse 2009 certificates, which are still in circulation because long-running projects may have certificates on file from years ago.

Fax artifacts - horizontal scan lines, compression artifacts, rotated pages - are common in insurance workflows because many brokers still fax certificates. A production COI parser needs to handle these gracefully rather than failing on degraded input.

How COI ParseAPI Handles Both Form Types

COI ParseAPI is built to handle both ACORD 25 and ACORD 28 forms, across multiple form versions, with production-grade handling of scanned and faxed PDFs. The API automatically detects the form type and returns appropriately structured JSON for each.

For an ACORD 25 parse, the response includes the full liability coverage breakdown:

{
  "form_type": "ACORD_25",
  "version": "2016/05",
  "named_insured": {
    "name": "Summit Roofing Partners LLC",
    "address": "850 Trade Center Dr, Nashville TN 37211"
  },
  "certificate_holder": {
    "name": "Meridian Property Group LLC",
    "address": "200 Fifth Avenue N, Nashville TN 37219"
  },
  "additional_insured": true,
  "waiver_of_subrogation": true,
  "primary_noncontributory": true,
  "coverages": {
    "general_liability": {
      "carrier": "Cincinnati Insurance Company",
      "naic": "10677",
      "policy_number": "CPP 002-44-19",
      "effective_date": "2026-01-01",
      "expiration_date": "2027-01-01",
      "per_occurrence": 1000000,
      "general_aggregate": 2000000,
      "products_completed_ops_aggregate": 2000000,
      "personal_advertising_injury": 1000000,
      "damage_to_rented_premises": 300000
    },
    "umbrella": {
      "carrier": "Cincinnati Insurance Company",
      "policy_number": "XS 003-22-09",
      "effective_date": "2026-01-01",
      "expiration_date": "2027-01-01",
      "each_occurrence": 5000000,
      "aggregate": 5000000,
      "follows_form": true
    },
    "workers_compensation": {
      "carrier": "State Auto Insurance",
      "policy_number": "WC-TN-9944-01",
      "effective_date": "2026-01-01",
      "expiration_date": "2027-01-01",
      "statutory_limits": true,
      "employers_liability_per_accident": 1000000
    }
  }
}

For an ACORD 28 parse, the response reflects the property-side structure:

{
  "form_type": "ACORD_28",
  "version": "2016/03",
  "named_insured": {
    "name": "Lakeview Commercial Properties LLC",
    "address": "5000 Corporate Blvd, Charlotte NC 28217"
  },
  "interested_party": {
    "name": "First National Bank of Charlotte",
    "address": "100 Trade St, Charlotte NC 28202",
    "relationship": "MORTGAGEE",
    "loan_number": "CRE-2024-00891"
  },
  "covered_locations": [
    {
      "location_number": 1,
      "address": "5000 Corporate Blvd, Charlotte NC 28202",
      "building_limit": 8500000,
      "valuation_basis": "REPLACEMENT_COST",
      "business_personal_property_limit": 750000,
      "business_income_limit": 1200000
    }
  ],
  "deductible": {
    "type": "ALL_PERILS",
    "amount": 25000
  },
  "carrier": "Zurich American Insurance Company",
  "policy_number": "CPO 9982-44-01",
  "effective_date": "2026-04-01",
  "expiration_date": "2027-04-01"
}

With structured JSON output for both form types, your compliance system, loan management system, or vendor portal can run automated checks without any manual reading. For ACORD 25, compare extracted limits against your minimum requirements. For ACORD 28, compare the building limit against the outstanding loan balance and verify the mortgagee name matches exactly. Both checks run in milliseconds once the parse is complete.

For a technical walkthrough of building a COI parsing integration, see How to Parse COI PDFs with a REST API: Integration Guide.

Conclusion

ACORD 25 and ACORD 28 are both standardized evidence documents, but they serve completely different purposes and grant completely different rights to the parties involved. ACORD 25 verifies liability coverage and can confer additional insured status; ACORD 28 evidences property coverage and names mortgagees and loss payees. Requesting the wrong form means getting useless paperwork. Reading either form without understanding its legal limitations means misplaced confidence in coverage that may not protect you.

For risk managers and compliance teams processing large volumes of certificates, the practical implication is that your parsing and verification system needs to handle both form types correctly - detecting which form you received, extracting the right fields for that form type, and running the appropriate compliance checks. A system that only handles ACORD 25 will fail silently on ACORD 28s, and vice versa.

The investment in getting this right pays off quickly. A single coverage dispute that hinges on whether an additional insured endorsement was actually in force - or whether a property's replacement cost limit was adequate at the time of a loss - can cost orders of magnitude more than the entire cost of building a proper COI compliance workflow.