Input from ACORD Regarding Recent Changes to the ACORD 25
ACORD recently released a new edition of the ACORD 25 (2025/12), now in use. Here is a clarification to any confusion about listing contract not policy limits.
ACORD recently introduced a new edition of its most popular evidence of insurance form. The new Certificate of Liability Insurance, ACORD 25 (2025/12), which is now in use.
The most significant changes are to the text in the box that begins with the words, “THIS IS TO CERTIFY …” The prior edition of the form ended the text in that box with, “LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.” The new edition added an asterisk (*) at the beginning of that sentence and adds a new sentence at the end: “LIMITS SHOWN ARE INCLUSIVE OF AMOUNTS REQUESTED BY THE CERTIFICATE HOLDER AND MAY NOT REFLECT POLICY LIMIT AMOUNTS IN EXCESS OF THOSE REQUESTED.”
This directive seems to suggest that a liability certificate could show the requested contract limits required applying to the project described in the body of the certificate, rather than those provided by the policy (assuming those are greater). The Big “I” New York and the National Big “I” still recommend that you continue to show the policy limits rather than those required by a contract. However, we also recommend you reach out to your state Big “I” to discuss if there is any state legislation that may affect this practice.
Response from ACORD
I reached out to ACORD and quickly received this response.
“We’ve had a few members reach out with the same concerns and have worked closely with our legal department regarding an appropriate response.
“The new sentence in the “THIS IS TO CERTIFY” paragraph — that limits shown are inclusive of amounts requested by the certificate holder and may not reflect policy limits in excess of those requested — was added to clarify existing industry practice, not to authorize anything false or misleading. The purpose is transparency: where a certificate holder requests confirmation of specific amounts to satisfy a contract (say, $1M GL) and the underlying policy carries more, the certificate may show the requested $1M rather than the full limit. The disclaimer makes that visible on the face of the certificate, so a holder does not assume the figure shown represents the policy maximum.
“Importantly, the limits shown remain accurate and available under the policy. A producer cannot show more than the policy actually provides, and nothing on the form permits an inaccurate statement. We filed the change as a regulatory filing in the states that require it — specifically to resolve the very ambiguity you raise about whether showing requested-versus-maximum amounts could be viewed as misleading under state COI statutes — and it was reviewed and approved by all applicable states. (It is also noted as not applicable in Wyoming.)
“On the point most relevant to your members: the language is permissive, not mandatory. It does not change any producer’s standard of care or require anyone to show less than actual policy limits. An agent who prefers to continue showing full policy limits, as many do, can absolutely keep doing so. The change simply clarifies that the requested-amount practice, where it is used, is transparent and accurate rather than a misstatement. As always, an agency’s specific certificate practices and E&O questions are best run by its own counsel or E&O carrier, but from ACORD’s side the form is built to support accuracy and disclosure.
“Please feel free to share this explanation with your members as ACORD’s written confirmation of the change and its intent.”
Below are links to Tim Dodge’s article, the Ed Director for New York Big “I” on the subject. Dodge is also a long-serving member of our Technical Affairs Committee that meets with Verisk annually to help enact form language improvements.
Here are Tim’s posts offering advice and links to his two posts. The first one was on March 10:
“This seems to imply that a certificate could show the insurance limits required by a contract that applies to the project described in the body of the certificate, rather than those provided by the policy (assuming those are greater). We consider it a good errors and omissions loss prevention practice to show the limits on the policy regardless of those required by a contract.
“The second one was three weeks later after another organization issued an alert scaring the heck out of every agency in New York,” according to Dodge.
“The new edition of ACORD 25 revised the wording regarding limits of insurance. Our advice remains that agencies should input the limits shown in the policy declarations in those fields, regardless of the new wording.”
We hope this article clarifies the still-recommended practice of listing policy limits, not contract limits, on the Liability certificate of insurance.
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