The ACORD 25 Is Not Insurance Verification

A broker I know called me six weeks after a cargo claim turned into a lawsuit naming him personally. The ACORD 25 in his carrier file was clean — MC active, authority verified, $250,000 cargo limit. More than enough for the $180,000 electronics load they'd booked. What he didn't know was that the carrier's cargo policy had a consumer electronics exclusion buried two pages into the endorsement schedule. The certificate said nothing about it. It never does.

He'd done what most brokers do: received the ACORD 25, confirmed the numbers looked right, saved it to the file, and moved on. He thought that was insurance verification. It wasn't. It was document collection.

Those aren't the same thing. And the difference between them matters even more now. After Montgomery v. Caribe Transport II, the Supreme Court ruled unanimously on May 14, 2026 that federal law does not preempt state-law negligent-selection claims. Brokers can now be sued in state court for what they failed to verify. A certificate in a file is not a verified insurance position. A plaintiff's attorney will make that point at length.

Here's what I actually look at on a COI, and what I've learned to check beyond it.

Five Fields That Actually Matter

Named insured vs. operating entity

The "Named Insured" box should match the legal entity holding the MC authority — not just a DBA, and not an individual's name when you're dealing with a corporate entity. Leased owner-ops and reorganized companies make this messy constantly.

Example: MC-1847392 / DOT-4129087. Authority is held by JDS Transportation LLC. The ACORD 25 comes in with the named insured listed as "John Smith dba JDS Transportation." That might be fine — or it might mean the policy covers John Smith as an individual and the LLC has no coverage at all. Those produce very different outcomes in a cargo dispute, and the certificate won't tell you which one you're dealing with.

When names don't match exactly, call the agency that issued the certificate and ask them to confirm that the named insured is the same legal entity as the MC holder. If they can't confirm it in ten seconds, document it and resolve it before the load moves.

Policy dates matched to the load date, not today's date

Most brokers confirm that today's date falls inside the coverage window. That's the floor. If you're booking a load that'll move in three weeks and the cargo policy expires in two, you're planning to tender freight to an uninsured carrier. I've seen it happen.

When you're running the vetting check, look at the actual ship and delivery dates on the load, not just the date you're running credentials. If you use a carrier regularly, calendar their policy expiration thirty days out so you're not scrambling the morning a load needs to move.

The coverage form and the MCS-90 endorsement

The commercial auto liability section should reference the MCS-90 endorsement — either in the description-of-operations box or in the covered forms list. The MCS-90 is the federally required endorsement under 49 CFR Part 387. Its job is to ensure that the liability insurer pays third-party bodily injury and property damage claims even when the carrier has violated policy conditions. Without it, coverage gaps that would normally let an insurer deny a claim can be used against the public.

Here's what the MCS-90 doesn't do: it doesn't cover cargo claims. Ever. The MCS-90 is a public liability tool — bodies, cars, buildings. Cargo moves under a separate Motor Truck Cargo policy with its own coverage terms, exclusions, and deductibles, and those terms are nowhere on the ACORD 25.

I say this because I watch brokers confuse cargo coverage and liability coverage constantly. The confusion is expensive.

Limits — and what they actually mean for your freight

49 CFR § 387.9 sets the minimums: $750,000 for general property carriers operating vehicles over 10,000 lbs GVWR, $1,000,000 for certain hazmat classifications. That's the statutory floor. Most serious shippers expect $1 million BIPD as the baseline, and on high-value lanes you should be asking for it as a condition.

Cargo limits are where it gets complicated. A $100,000 cargo limit sounds adequate until you learn the carrier has a $75,000 per-occurrence deductible. That deductible is not on the ACORD 25. At that point, the carrier is effectively self-insuring the first $75,000 of every claim — which means for most practical losses on a single load, you're relying on their bank account. If you're booking a load worth $80,000, "I had a certificate showing $100K cargo limits" is not going to be a satisfying answer when the claim doesn't get paid.

One more thing worth noting: the "General Liability" line on the ACORD 25 is not cargo coverage. GL covers bodily injury and property damage arising from operations. It doesn't respond to freight in transit. I've seen brokers point to a carrier's $1 million GL limit as evidence of adequate coverage for a cargo claim. It's not. They're unrelated.

Certificate holder designation

Your brokerage should be named as a certificate holder. This gets you a copy of the ACORD 25 and theoretically triggers cancellation notification. Note the "theoretically" — the cancellation-notification language on most certificates is aspirational wording, not a contractual guarantee. Insurance companies do not have great track records on proactive notification.

Being listed as certificate holder also does not make you an additional insured on the carrier's policy. You're not covered under the carrier's coverage just because your name is in that box. If you want additional insured status on a carrier's liability policy, you need to specifically request it and see it confirmed in writing — and many carriers won't agree to it.

What the ACORD 25 Won't Tell You

This is where brokers get burned.

Whether the policy is actually in force. The ACORD 25 is issued by the carrier's insurance agent. It's a representation of what the policy says — not confirmation that premium is current or that the policy is still active. Carriers have used fabricated certificates. Not often, but it happens. The FMCSA's Licensing and Insurance database (accessible through SAFER or directly via the L&I search) shows filings made directly by insurers — BMC-91 forms for liability, separate cargo filings for Motor Truck Cargo policies. If the insurer filed it and it shows active in L&I, that's verification. The certificate your carrier emailed you is not.

Exclusions that gut the coverage. I already mentioned consumer electronics. Add refrigerated goods, alcohol, pharmaceuticals, jewelry, fine art, and anything else an underwriter has decided is too high-risk or too niche for standard cargo coverage. These exclusions can eliminate coverage entirely for specific freight types. None of them appear on the ACORD 25. If you regularly move specialty or high-value freight, ask the carrier for their Motor Truck Cargo policy declarations page and read it. The extra five minutes has saved me more than once.

Whether a claim will actually get paid. A carrier whose premium is in arrears technically has coverage that still shows active in L&I — right up until the moment the insurer voids the policy. That retroactive rescission can happen after your loss date. The certificate looked fine. The L&I showed active. And then it didn't. This scenario is rare, but it's also the scenario discovery finds when a claim is contested.

What Actually Counts as Verification

The ACORD 25 is the starting point. Here's what comes after it for any carrier I'm using for the first time.

Pull the FMCSA L&I record directly — not from the carrier, not from a monitoring tool's snapshot, but from the FMCSA database directly, on the day you're running the vetting. I'm looking for active insurance filings from the insurer. The policy numbers should match what's on the ACORD 25. When they don't, I make a call before tendering.

For any load over $100,000 in cargo value, I call the insurer directly. I use the phone number from the L&I filing, not the number on the certificate — those have been different before, and the number on the certificate sometimes reaches an agency or broker who can't give you binding confirmation. I ask whether the policy is active, whether the named insured matches the entity tendering freight, and whether there are commodity exclusions relevant to the freight type I'm moving. I write down who I spoke with, what they said, and when.

If anything is mismatched — names, dates, policy numbers — I resolve it before the load moves. Not after. Discovery is linear. The sequence of events is permanent.

How I Document This

For every new carrier, my insurance verification note includes:

The ACORD 25, saved with the date and time it was received. The L&I lookup result — screenshot or PDF — pulled on the vetting date. The policy numbers I confirmed and how I confirmed them (database match, phone verification, or both). Any discrepancy I found and how I resolved it. For high-value loads, the name and direct line of the person at the insurer I spoke with.

If I find a mismatch and the carrier corrects it, that gets documented too. A file that shows I identified a problem and resolved it before tendering looks completely different under deposition than a file that's silent on the issue. The silence gets interpreted as indifference.

The certificate is a piece of paper. Insurance is a contract. Verify the contract, document the verification, and keep the paper as backup — not the other way around.

— Mason Lavallet

Founder, DOTScreener.com