COI Records for 1099 Contractors

A certificate of insurance is a one-page summary document — typically an ACORD 25 form — that confirms a contractor or subcontractor carries active insurance coverage. It lists the insured's name, the types of coverage in force (workers' compensation, general liability, commercial auto, etc.), the policy numbers, the coverage limits, and the expiration dates of each policy.

A COI is not the policy itself. It does not guarantee coverage in every scenario. But it is the standard proof of insurance that every business should require before a contractor sets foot on a job site, enters a client's property, or begins any work performed on your behalf.

Workers' Compensation Audit Exposure. Florida law requires most employers to carry workers' compensation insurance. When your policy renews, your carrier conducts a premium audit — a review of your actual payroll and subcontractor payments during the policy period. If you paid a subcontractor who did not carry their own workers' comp policy, your carrier will treat those payments as your uninsured payroll and charge you the corresponding premium at your class code rate.

For a roofing company, a landscaping business, or any trade contractor, this can mean a four- or five-figure audit bill for a single uninsured sub. The only way to avoid it is to have a valid COI on file proving the sub carried their own workers' comp coverage for the period they worked for you.

Florida-specific note: Florida's workers' compensation exemption system adds a layer of complexity. Sole proprietors and certain corporate officers can file for a workers' comp exemption, but exemptions have coverage limits and do not apply to all trades. A COI showing an exemption certificate is not the same as a COI showing active workers' comp coverage.

General Liability Pass-Through Claims. If a subcontractor causes property damage or bodily injury while working on your behalf, the injured party will frequently name you in the lawsuit — not just the sub. When you have a COI on file and the sub is listed as carrying adequate general liability coverage, you have a documented basis to tender the claim to the sub's carrier first. Without that documentation, you are the last line of defense.

Contract and Client Requirements. If your business works with general contractors, property managers, municipalities, or commercial clients, your contracts almost certainly require you to ensure that any subcontractors you use carry minimum insurance limits. Failing to collect and verify COIs puts you in breach of those contracts — even if no claim ever occurs.

When requesting a certificate of insurance from a 1099 contractor or subcontractor, verify the following before accepting it:

Item	What to Check
Named insured	The name on the COI must match the legal name of the entity you are paying. A COI in a different name is not valid proof for your records.
Coverage types	At minimum: workers' compensation (or a valid exemption) and general liability. Require commercial auto if the sub drives on your behalf.
Coverage limits	Match the limits to your contract requirements. A $300,000 GL limit may not satisfy a client that requires $1,000,000 per occurrence.
Policy dates	The policy must be active for the entire period the sub is working for you. A COI that expires mid-project is not adequate.
Additional insured	For general liability, many contracts require that your business be listed as an additional insured on the sub's policy.
Certificate holder	Your company name and address should appear in the certificate holder field.

Step 1: Make COI Collection a Condition of Payment. The single most effective policy is simple: no COI, no check. Before issuing any payment to a 1099 contractor or subcontractor, require a current COI on file. Build this into your onboarding checklist and your accounts payable process.

Step 2: Create a Centralized COI Log. Maintain a master spreadsheet that lists every active contractor and subcontractor with their workers' comp carrier, policy number, expiration date, general liability carrier, policy number, expiration date, and the date the COI was received. Review this log at least monthly and flag any certificates expiring within 30 days.

Step 3: Store COIs in a Dedicated, Accessible Location. Whether you use a shared drive, a cloud storage folder, or a project management platform, COIs should be stored in a single location that your office staff, project managers, and accountant can access. Name files consistently — for example, SMITH_ROOFING_COI_2026.pdf — so they are easy to locate during an audit.

Step 4: Set Expiration Reminders. Calendar reminders 45 and 15 days before each COI expiration date give you enough lead time to request a renewal without disrupting a project. Many insurance agencies will send updated certificates automatically when a policy renews — but do not count on it.

Step 5: Keep Records for at Least Three to Five Years. Workers' compensation audits can look back multiple policy periods. General liability claims can surface long after a project is complete. Retain COIs for a minimum of three years after the last date the contractor performed work for you, and five years if your contracts require longer retention.

Accepting expired certificates. Always check the expiration date. A COI from last year proves nothing about current coverage.

Accepting certificates without verifying the named insured. If a sub operates under a DBA or a different LLC than the one on the COI, the certificate may not protect you.

Assuming an exemption equals coverage. In Florida, a workers' comp exemption means the owner has opted out of coverage for themselves — it does not mean their employees are covered. If the sub has employees, those employees must be covered by a workers' comp policy.

Collecting COIs only at the start of a relationship. A contractor who was insured when you first hired them may have let their policy lapse. Annual re-verification is the minimum; quarterly is better for high-volume relationships.

Relying on verbal assurances. "I have insurance" is not documentation. A certificate of insurance is documentation.

If you are a Florida business owner managing a roster of subcontractors and 1099 workers, Bright Coast Insurance can help you understand your workers' compensation and general liability exposure, ensure your policy is structured correctly to account for subcontractor payments, and guide you on the coverage requirements you should be demanding from the subs you hire.

We work with contractors, property managers, staffing companies, and small businesses across Florida — from Miami to Jacksonville, Tampa to Orlando — and we understand how Florida's workers' comp audit process works and what it takes to protect your business from surprise charges.