Can a COI Promise 30 Days' Cancellation Notice? A Texas Example

The ACORD 25 form describes itself as "issued as a matter of information only," says it "confers no rights upon the certificate holder," and says it "does not affirmatively or negatively amend, extend or alter the coverage afforded by the policies." Its cancellation box then points back to "the policy provisions." Read together, the form reports the notice terms. It does not add any.

State law can make the same point binding. In Texas, a certificate "is not a policy of insurance" and "does not amend, extend, or alter the coverage" (§1811.152). In New York, a certificate "shall further not confer to any person any rights beyond those expressly provided by the policy," and no one may wilfully require certificate language the policy does not expressly include (New York Insurance Law §502).

A contract clause that says "the certificate shall provide 30 days' notice of cancellation" is asking the certificate to deliver something only the policy can. The practical question is whether the policy will.

Texas law sets notice rules for the policyholder, not for certificate holders. For general liability, commercial auto liability, non-medical professional liability, commercial multiperil and commercial property policies:

• An insurer must deliver or mail written notice of cancellation to the first-named insured at least 10 days before the cancellation takes effect (§551.053).
• An insurer that refuses to renew must send written notice to the first-named insured at least 60 days before the policy expires (§551.054).
• After the 60th day of the first policy term, and on renewal policies, an insurer may cancel only for reasons such as fraud in obtaining coverage, failure to pay premiums, an increase in hazard within the insured's control, or loss of reinsurance (§551.052).

These notices go to the first-named insured at the address on the policy. Nothing in these sections sends a copy to the businesses holding certificates. If your contract needs you to hear about a cancellation, that has to come from an endorsement, or from the insured passing on its own notice.

Surplus lines policies are different

Chapter 551 defines "insurer" as a company "admitted to engage in business" in Texas. TDI's general liability guide states that "Texas laws regarding notice of cancellation and nonrenewal do not apply to surplus lines insurers," and that "in some cases, a surplus lines insurer can cancel before a policy's renewal date" (TDI commercial general liability guide). If a certificate lists a surplus lines insurer, ask the agent what notice terms the policy itself contains.

The Texas test describes the endorsement you are looking for. It has to do two things: name your business, and require the insurer to send you notice. Ask the agent for that endorsement by form number and edition date, then check:

• Who is named. Is your business named, or does the wording refer only to a list or a description? Texas requires the person to be "named within the policy or an endorsement."
• Which events. Does it cover cancellation only, or also nonrenewal and material change?
• How many days. Is the number of days the same for every reason, including nonpayment of premium?
• Which policies. ACORD 25 lists general liability, auto, umbrella and workers' compensation in separate rows, each with its own policy number. Where they are separate policies, each needs its own notice wording if your contract asks for notice on each.
• How notice is sent. Which address or email will the insurer use, and who keeps it current?

Additional insured status is a separate question. An additional insured endorsement names you for coverage, but under §1811.155 the policy, endorsement or a law must also require notice. Being named for coverage does not settle the notice question.

This is a hypothetical example. A general contractor in Texas signs a subcontract that requires each subcontractor to give 30 days' written notice of cancellation to the contractor. A roofing subcontractor's agent issues an ACORD 25 that lists the contractor as certificate holder. The cancellation box carries the standard "in accordance with the policy provisions" wording.

The contractor asks the subcontractor for the notice endorsement. If the policy has one that names the contractor and requires 30 days' notice, a Texas certificate may contain that information and may cite the applicable statute or rule (TDI FAQ). If the policy has no such endorsement, the certificate cannot add it. The parties then decide whether the subcontractor can obtain an endorsement, whether the contract terms need to change, or whether the contractor will track expiration and renewal dates itself.

For that last option, our subcontractor COI tracking system and mid-project renewal guide set out the steps.

Work through each item with the policy documents, not the certificate alone.

1. What does the certificate say?

• Does the cancellation box use the standard ACORD wording, or a different statement?
• Does any remark cite an endorsement form number or a statute?

2. Is your business named in the policy or an endorsement?

• Do you have the endorsement page that names you?
• Is the insurer licensed in the state, or a surplus lines insurer?

3. Does the policy, an endorsement or a law require notice to you?

• Which events does it cover: cancellation, nonrenewal, material change?
• How many days, and does that differ by reason?

4. Does the certificate mirror the policy?

• Does the certificate match the endorsement, or does it promise more?
• Has the agent confirmed the wording in writing?

5. Record the result.

• Endorsement form number and edition, policy number and expiration date.
• Who will check the renewal certificate, and when.

• Does any of my policies include an endorsement that names a certificate holder and requires notice to it? Which form?
• If my contract requires 30 days' notice, can the insurer add an endorsement for this customer, and does it cover every policy on the certificate?
• Is any policy on this certificate written by a surplus lines insurer, and what notice terms does it contain?
• How will I learn if a notice is sent to my customer?

For the coverage most certificate requests involve, see the general liability coverage page. For the Texas rule on blanket endorsements, read Texas COIs and blanket additional insured endorsements. If you want PolicyBenchmark to follow up about your coverage, request coverage help.

Sources checked October 3, 2026. Texas statutes are the worked example; for another state's notice rules, ask that state's insurance department.