Short answer
Most rejected oilfield certificates fail for one of a handful of reasons: the named insured does not match the company that signed the MSA, required endorsements (additional insured, primary and non-contributory, waiver of subrogation) are not shown or not attached, a limit is short, the umbrella does not cover what the MSA requires, a policy is expired, or the certificate holder is wrong.
- Fixing it usually means fixing the policy, not the certificate. In Texas a certificate cannot change coverage, and an ACORD 25 says so on its face.
What a certificate can and cannot do
The ACORD 25 is a summary. Its header reads: "THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW."
Texas law backs that up. Insurance Code Chapter 1811, added in 2011, says an insurer or agent may not issue a certificate that "alters, amends, or extends the coverage or terms and conditions" of the policy, that a certificate "may not convey a contractual right to a certificate holder," and that certificates must be on a filed and approved form (standard forms such as ACORD's are deemed approved when filed). It also bars anyone from requiring a certificate that contains false or misleading information about the policy.
That is why reviewers increasingly ask for endorsement copies, and why an agent cannot simply type the operator's wording into the description box to make a problem go away.
Sample certificate: where reviews fail
- 1Named insured mismatch. The certificate says "LLC," the MSA was signed by the "Inc." Reviewers match names exactly, including DBAs.
- 2AI and waiver boxes blank. ADDL INSD and SUBR WVD are empty on the general liability line, so the reviewer cannot see the operator is covered.
- 3Auto symbol too narrow. Only scheduled autos are shown. Most MSAs want any auto, or owned plus hired and non-owned.
- 4Umbrella limit short. A $2M umbrella against a $5M requirement fails, even when everything else is right.
- 5Workers comp waiver and EL limits. No waiver of subrogation on comp, and employers liability at $500K where $1M is commonly required.
- 6Description of operations too vague. "Holder is additional insured" with no mention of primary and non-contributory, completed operations, or the endorsement forms.
- 7Notice of cancellation. The certificate itself cannot promise 30 days notice. That takes an endorsement on the policy, and reviewers know it.
The common rejection reasons
Here is what we see most often, and what actually fixes each one.
| Rejection reason | What it usually means | Fix |
|---|---|---|
| Named insured does not match | The MSA was signed by an LLC, but the policies are in an owner's name, a DBA, or a sister company | Add or correct the named insured on every policy so it matches the contracting entity exactly |
| Additional insured not shown or not supported | The ADDL INSD box is checked but no endorsement is attached, or the endorsement does not reach the operator | Blanket or scheduled AI endorsement on GL, auto and umbrella; attach copies |
| Primary and non-contributory missing | The MSA requires your policy to respond first without sharing with the operator's insurance | Endorsement wording that makes coverage primary and non-contributory where required by written contract |
| Waiver of subrogation missing | SUBR WVD box checked without the endorsement, or missing on comp | Waiver endorsements on GL, auto and comp (in Texas, WC 42 03 04) |
| Limits short | GL, auto, EL or umbrella below the MSA exhibit | Raise the limit, or confirm the MSA allows primary plus umbrella to combine |
| Umbrella does not follow form | Umbrella is not over all required lines, or does not pass AI/waiver to the operator | Confirm the umbrella schedule of underlying and its AI and waiver terms |
| Expired or pending dates | A policy expired, or renewal is bound but not shown | Issue a new certificate when the renewal binds; do not wait for the platform to flag it |
| Wrong certificate holder | Holder is a field office or old entity name instead of the name the operator specifies | Use the exact holder name and address from the operator or platform instructions |
| Cancellation wording | The operator wants 30-day notice promised on the certificate | Notice comes from the policy or an endorsement; the ACORD box only refers to policy provisions |
| Pollution or auto symbol | No pollution coverage shown, or auto limited to scheduled autos when the MSA wants any auto or hired/non-owned | Add pollution coverage and adjust auto symbols to match |
The two that cause the most rework
Name mismatch. Oilfield companies often grow from a sole proprietor into an LLC, then add a second LLC for trucks or equipment. If the operator signed with "Smith Well Service, LLC" and the certificate says "John Smith dba Smith Well Service," the reviewer is right to reject it. The MSA's insurance requirements are owed by the contracting entity, so that entity needs to be a named insured on every policy.
Endorsements not attached. The ACORD 25 itself says that if the holder is an additional insured, "the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed," and that a waiver statement on the certificate "does not confer rights to the certificate holder in lieu of such endorsement(s)." Reviewers know this, so they ask for the endorsement pages. If your agent sends only the ACORD, expect a deficiency. See what primary and non-contributory means and blanket additional insured endorsements.
About the "30 days notice of cancellation" request
Older ACORD 25 editions said the insurer would "endeavor to mail" notice of cancellation. The current form says notice "will be delivered in accordance with the policy provisions." Under Texas law, a person has a legal right to notice of cancellation only if they are named in the policy or an endorsement and the policy, endorsement or a law requires that notice, and a certificate may not alter the notice terms. So if an operator requires advance notice, the fix is a notice-of-cancellation endorsement on the policy (where the carrier offers one), not new words on the certificate.
If your grade already dropped
Fix the policy first, then re-issue one clean certificate with the endorsement pages attached, and upload it through the platform's process. For platform-specific steps, see what happens if your ISNetworld insurance grade drops and our Avetta insurance requirements page.
Common questions
Can my agent add the operator's required wording to the certificate?
Only to describe coverage that already exists on the policy. In Texas, a certificate may not alter, amend or extend the policy, so required wording has to be backed by an actual endorsement.
Why do they want endorsement copies if the ACORD already shows the boxes checked?
Because the ACORD 25 says it confers no rights and that additional insured and waiver status depend on the policy being endorsed. The endorsement is the proof.
My policy renewed but the platform shows it expired. What happened?
The platform only knows what was uploaded. A new certificate showing the renewal dates has to be issued and submitted after the renewal binds.
Does the certificate holder have to be the exact legal name?
Usually yes. Operators and platforms often specify the holder name and address, and a mismatch is a common deficiency.
Sources
- ACORD 25 (2016/03) Certificate of Liability Insurance, specimen posted by NY Office of General Services. Disclaimer that the certificate confers no rights and does not amend coverage; additional insured and waiver notes; current cancellation wording.
- Texas S.B. 425 (82nd Leg., 2011), enrolled text adding Insurance Code Chapter 1811. Certificates may not alter coverage or convey contractual rights; approved forms; no false or misleading certificates; notice of cancellation rights.
- BCS, How the ACORD changes affect vendor screening (2011). Old "endeavor to mail" cancellation wording vs. the 2009/09 "in accordance with the policy provisions" wording.
- Texas Department of Insurance, Texas workers comp endorsements (WC 42 03 04 A). Texas waiver of subrogation endorsement for workers comp.
This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.
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