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Endorsements

CG 20 10 vs CG 20 37: ongoing and completed operations

Updated · 9 min read

Short answer

CG 20 10 makes you an additional insured on a subcontractor's general liability policy for injury or damage the subcontractor causes, at least in part, during its work for you. CG 20 37 does the same for injury or damage that happens after that work is finished. Current editions of CG 20 10 leave finished work out, so a contract that requires both needs both forms, or an equivalent form that grants both.

What each form does

Both are endorsements: pages attached to a subcontractor’s commercial general liability policy that change its terms. Insurance Services Office (ISO) publishes them. Each makes you an additional insured on that policy, for a different stretch of time.

CG 20 10 is titled Additional Insured - Owners, Lessees or Contractors - Scheduled Person or Organization. It covers you for injury or damage caused, in whole or in part, by the subcontractor or those acting for it during its ongoing operations for you. It excludes injury or damage that happens after the work on the project is complete, or after the part involved has been put to its intended use.

CG 20 37 is titled Additional Insured - Owners, Lessees or Contractors - Completed Operations. It covers you for injury or damage caused, in whole or in part, by the subcontractor’s finished work at the location the endorsement names.

That is how editions from 2004 on read. Earlier ones differ, as the table of editions below shows. An insurer may issue a form of its own instead, and your broker can tell you whether it gives equivalent coverage. The help center guide Additional insured endorsements explains what an additional insured is, and why a checked box on a certificate does not make you one.

The two forms side by side

CG 20 10 and CG 20 37 compared
CG 20 10CG 20 37
OperationsOngoing: the work while it is under wayCompleted: the work after it is finished
Covers you forInjury or damage the subcontractor causes, at least in part, while working for youInjury or damage its finished work causes, at least in part
Stops applyingTo injury or damage after the work is complete or in useWhen the policy it is on ends, unless the next policy carries it too
Its schedule showsYour name and the location of the covered operationsYour name, and the location and description of the completed operations
Automatic (blanket) versionCG 20 33 or CG 20 38CG 20 39 or CG 20 40

A timeline: an injury during the work, a leak two years after handover

The project and the dates here are made up.

A made-up project
WhenWhat happensForm that applies
June 2026During the plumbing work on your apartment project, a delivery driver trips over pipe the crew left across a corridor, and sues youCG 20 10 on the plumber's 2026 policy: the injury happened during the work and the crew had a part in it
December 2026The building is handed over and tenants move inCG 20 10 does not apply to injury or damage from here on
January 2029A joint the plumber installed fails and floods two apartments. The owner claims against youCG 20 37, and only if it is on the plumber's policy in force in January 2029

With CG 20 10 alone, you have no additional insured status for the leak. With CG 20 37 on the 2026 policy but dropped at a later renewal, you have none either. For completed operations, the date that counts is when the damage happens, not when the work was done. Neither form promises payment: the rest of the policy and the facts decide that.

Why the edition date matters

ISO revises its forms. The form number stays the same and the edition date changes. The date is printed after the number as month and year: CG 20 10 04 13 is the April 2013 edition. Find the date on the endorsement you are sent, then read its row.

What changed in each edition
EditionWhat changedWhat it means for you
11 85CG 20 10 covered liability arising out of the subcontractor's work, in progress or finishedOne form did both jobs. It has been hard to obtain for years, though some contracts still ask for it
10 93The wording was narrowed to ongoing operationsFinished work was meant to be left out
10 01CG 20 10 spelled out an exclusion for injury or damage after the work is complete or in use. CG 20 37 was introduced for completed operationsYou need two forms from here on
07 04The test changed from liability arising out of the work to liability “caused, in whole or in part, by” the subcontractor (CG 20 10) or its work (CG 20 37)Written to leave out an injury that is your fault alone
04 13Coverage applies only as far as the law permits and is no broader than your contract requires. The insurer pays no more than the lower of the amount your contract requires and the policy limitYour subcontract sets the ceiling. What it leaves vague, you may not get
12 19The wording of the cap on limits was revised. Automatic forms for completed operations were issuedThe 04 13 limits still apply

After 12 19

12 19 is the latest edition we could confirm. ISO announced a general liability forms revision for policies written from 1 October 2026, and we could not confirm whether it touches these two forms. If an endorsement arrives with a later date, ask the agent what changed.

The automatic forms: CG 20 33, CG 20 38, CG 20 39 and CG 20 40

CG 20 10 and CG 20 37 are scheduled: they name you. ISO’s automatic forms for construction, also called blanket, name nobody. They apply to whoever a written construction agreement requires the subcontractor to add. Each title begins “Additional Insured - Owners, Lessees or Contractors”. The rest of each title, as printed on the 04 13 and 12 19 editions, is in the table.

The four automatic forms
Form and titleOperationsWho it reaches
CG 20 33, Automatic Status When Required in Construction Agreement With YouOngoingA party the subcontractor works for and has agreed with, in writing, to add
CG 20 38, Automatic Status for Other Parties When Required in Written Construction AgreementOngoingThat party, and others the same agreement requires, such as the owner
CG 20 39, Automatic Status When Required in Written Construction Agreement With You (Completed Operations)CompletedAs CG 20 33. First issued 12 19
CG 20 40, Automatic Status for Other Parties When Required in Written Construction Agreement (Completed Operations)CompletedAs CG 20 38. First issued 12 19

You contract with the subcontractor directly, so any of the four can reach you. Where the owner has no contract with the subcontractor, only CG 20 38 and CG 20 40 are written to reach the owner. All four depend on the written agreement: keep the signed subcontract with the endorsement.

Watch for

CG 20 33 and CG 20 38 end when the subcontractor’s operations for you are completed. If the policy carries one of them and nothing else, look for a second form. That can be CG 20 37 naming you, CG 20 39 or CG 20 40, or an insurer’s own form that says completed operations in its text.

How long to require completed operations coverage

CG 20 37 works only while it is on the policy in force when the damage happens. The subcontractor therefore has to carry it, or an equivalent, at each renewal. Since 04 13 the form gives no more than your contract requires, so the subcontract has to say for how many years.

The number can be a fixed period, or the length of your state’s statute of repose. That is the law that bars a claim over a building once a set number of years has passed, counted from an event the statute names. Virginia’s is five years and Florida’s is seven, counted from different events, and not every state has one. Which period fits is a question for your construction attorney, and whether subcontractors’ insurers will provide it for that long is one for your broker. The worksheet in the sample insurance requirements has a row for the number.

What to ask the subcontractor’s agent for

  • A copy of each additional insured endorsement on the general liability policy, not a certificate that mentions it.
  • For ongoing operations: CG 20 10 naming you, or CG 20 33 or CG 20 38, or an equivalent form the insurer issues.
  • For completed operations: CG 20 37 naming you and the project, or CG 20 39 or CG 20 40, or an equivalent form the insurer issues.
  • The edition date on each, checked against the edition your subcontract names.
  • If the owner must be covered too, whether an automatic form reaches the owner.
  • The same pages at each renewal, for as long as your subcontract requires completed operations coverage.

The one-page sheet for a subcontractor’s agent is a place to list them. An endorsement narrower than your subcontract is a gap to take to your broker and your attorney. This guide covers US forms and is general information, not insurance or legal advice.

Key takeaways

  • CG 20 10 covers you while the subcontractor is working, CG 20 37 after the work is finished. A contract that requires both needs both.
  • For completed operations, the policy that counts is the one in force when the damage happens. The endorsement has to be renewed for as many years as your contract says.
  • Read the edition date. From 07 04 the injury or damage must be caused, at least in part, by the subcontractor. From 04 13 the form gives no more than your contract requires.
  • CG 20 33 and CG 20 39 reach only a party in direct contract with the subcontractor. CG 20 38 and CG 20 40 also reach other parties the agreement requires, such as the owner.

Common questions

Does CG 20 10 cover completed operations?

Not in current editions. The 11 85 edition covered liability arising out of the subcontractor’s work, which included finished work. Editions from 10 01 on exclude injury or damage that happens after the work is complete or has been put to its intended use. For completed operations you need CG 20 37 or an equivalent form.

What is the difference between CG 20 10 07 04 and CG 20 10 04 13?

Both cover you only for injury or damage caused, in whole or in part, by the subcontractor during its ongoing operations. The 04 13 edition adds three limits. Coverage applies only as far as the law permits. It is no broader than your contract requires. The insurer pays no more than the lower of the amount your contract requires and the policy limit. Under 04 13, a vague contract can leave you with less.

Is CG 20 38 enough on its own?

For ongoing operations it can be. CG 20 38 gives automatic additional insured status to a party the subcontractor has agreed in writing to add, and to other parties that agreement requires. It ends when the subcontractor’s operations are completed, so for completed operations you still need CG 20 37, CG 20 39, CG 20 40 or an equivalent form.

My contract asks for CG 20 10 11 85. What should I accept?

The 11 85 edition has been hard to obtain for years, so an agent may not be able to supply it. The current forms that cover the same two periods are CG 20 10 with CG 20 37, and they are narrower. Since 07 04 they apply only where the subcontractor caused the injury or damage, at least in part. Whether to accept that pair, and whether to change the contract wording, is a decision to make with your attorney and your broker.

Sources

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