CG 22 94 Explained: What This Subcontractor Exclusion Means for General Contractors
Key Takeaways
CG 22 94 removes coverage for property damage caused by your subcontractors' completed work — one of the most common sources of general contractor liability claims.
The exclusion also eliminates your right to a legal defense for those claims — meaning you pay attorney fees out of pocket even if you ultimately win.
Carriers are applying this exclusion more frequently in tighter markets — it is often added at renewal without the contractor fully understanding what has been removed.
A certificate of insurance from your subcontractor does not protect you from this exclusion — the fix requires action on your own policy, not your sub's.
If you are a general contractor who hires subcontractors, there is a good chance your general liability policy has quietly had a significant piece of coverage removed from it. The endorsement responsible is called CG 22 94 — formally titled the Exclusion of Damage to Work Performed by Subcontractors on Your Behalf — and most contractors do not know it is in their policy until a claim is denied.
This article explains exactly what CG 22 94 does, why carriers are using it more frequently, how it interacts with completed operations coverage, and what you can do to protect yourself. If your broker has never specifically discussed this endorsement with you, that conversation is overdue.
What CG 22 94 Actually Does
To understand CG 22 94 you first need to understand the coverage it is removing. Standard commercial general liability policies include what is called the products-completed operations hazard — coverage for bodily injury and property damage that occurs after your work is finished and the project has been turned over to the owner. This is completed operations coverage, and for general contractors who hire subcontractors, it is one of the most important coverages in the policy.
Within the standard CGL policy there is an exclusion that bars coverage for damage to your own work arising out of that work. However, the standard policy includes an important exception to that exclusion — damage that was caused by a subcontractor working on your behalf is still covered. That exception is what allows a general contractor to have coverage when a subcontractor's faulty work causes property damage after project completion.
CG 22 94 removes that exception. When this endorsement is added to your policy, the subcontractor carve-back disappears — and with it, the completed operations coverage for damage caused by your subcontractors' work. The result is that if a subcontractor's faulty work causes property damage after project completion, your CGL policy will not respond to that claim. The carrier will deny coverage based on the endorsement.
Just as importantly, the endorsement also removes your right to a legal defense for those claims. Defense costs — attorney fees, expert witnesses, deposition costs — are covered by your CGL policy independently of whether the claim is ultimately paid. When CG 22 94 eliminates coverage for the underlying claim, it eliminates the defense obligation as well. That means you are paying out of pocket to defend a claim that your policy will not indemnify, which can cost tens of thousands of dollars even on claims that are ultimately resolved in your favor.
A Real World Example
You are a general contractor who built a commercial building two years ago. The electrical work was performed by a licensed subcontractor. The building owner calls to report that a wiring defect caused a fire that damaged a significant portion of the building. They are looking to you, as the GC, for compensation.
Without CG 22 94 on your policy:
Your CGL policy responds to the claim. Your carrier defends you, covers the cost of the investigation, and ultimately pays the settlement or judgment — then pursues the electrical subcontractor's carrier for reimbursement. Your out of pocket cost is limited to your deductible.
With CG 22 94 on your policy:
Your carrier denies the claim citing the CG 22 94 endorsement. You are responsible for your own legal defense costs and any settlement or judgment. If the electrical subcontractor's policy has adequate limits and does not have its own exclusions, you may be able to pursue them — but you are doing so with your own money while the litigation is active. If the subcontractor's policy is inadequate, has lapsed, or has exclusions of its own, you may have no recovery at all.
Why Carriers Are Using This Exclusion More Frequently
The increasing use of CG 22 94 is a market response to losses. Carriers who write general contractor CGL policies have taken significant hits from completed operations claims tied to subcontractor work — particularly in residential construction, where water intrusion, fire, and structural defect claims involving multiple subcontractors have been expensive and difficult to resolve. Rather than exiting the market entirely, carriers began adding CG 22 94 to manage their exposure.
The endorsement is particularly common in the excess and surplus lines market — the specialty market where contractors with difficult risk profiles, certain project types, or loss histories are placed when standard carriers decline to write them. If your policy has been placed in the E&S market, the likelihood of encountering CG 22 94 or a proprietary equivalent is higher than in the admitted market.
It also appears more frequently at renewal than at inception — carriers who have been writing a contractor's account may add the endorsement when renewing rather than when initially placing coverage, particularly if the contractor's loss history has developed or if the carrier's underwriting appetite has shifted. Many contractors are unaware the endorsement was added at renewal because they do not read the endorsement schedule carefully when they receive their renewal documents.
How CG 22 94 Interacts with Completed Operations Coverage
Completed operations coverage is the component of a CGL policy that covers claims arising after project completion — the long tail of construction liability. For general contractors, completed operations exposure is significant because construction defect claims frequently surface months or years after a project is finished and occupied. The standard completed operations aggregate limit is the pool of coverage available for all such claims during the policy period.
CG 22 94 does not eliminate completed operations coverage entirely — it eliminates it specifically for claims caused by subcontractor work. Claims arising from defects in the GC's own self-performed work are still covered under the completed operations coverage. The practical impact of this distinction depends on how much of the contractor's work is self-performed versus subcontracted.
For a general contractor who self-performs most of their work and uses subcontractors only occasionally, CG 22 94 may leave a manageable gap. For a general contractor who operates primarily as a manager of subcontracted trades — which describes many commercial GCs — CG 22 94 effectively eliminates the most significant portion of their completed operations coverage. In that scenario, the completed operations aggregate limit they are paying for provides far less protection than they likely understand.
Not sure if CG 22 94 is on your policy?
Send me your declarations page and I will tell you exactly what you have. justin@fstwest.com
What a Certificate of Insurance From Your Sub Does Not Do
One of the most common misunderstandings about CG 22 94 is that collecting certificates of insurance from subcontractors solves the problem. It does not — and understanding why is important.
A certificate of insurance confirms that your subcontractor had a policy in force on the date the certificate was issued. It does not guarantee that the subcontractor's policy will respond to a specific claim. It does not confirm the subcontractor's policy limits are adequate. It does not protect you from a denial under your own policy's CG 22 94 endorsement.
When a completed operations claim arises from subcontractor work and your own carrier denies coverage under CG 22 94, your path to recovery runs through the subcontractor's policy — not your own. That path has several potential obstacles. The subcontractor's policy may have lapsed. Their completed operations limits may be inadequate for the size of the claim. You may not be named as an additional insured on their completed operations coverage. Or their policy may include exclusions that bar the specific claim. Any one of those conditions can leave you without a meaningful recovery even when the subcontractor was clearly at fault.
Collecting certificates is a necessary minimum — but it is not a substitute for having the CG 22 94 issue addressed in your own program. The fix for this exposure lives in your policy, not your subcontractors'.
What You Can Do About It
There are several approaches to managing the CG 22 94 exposure. Some require action on your own policy. Others involve how you structure your subcontractor agreements.
Find a carrier that does not use CG 22 94. The most effective solution is placing your CGL with a carrier that does not apply this endorsement. In the admitted market, carriers with strong appetites for general contractor risks often write policies without CG 22 94. Working with a broker who has access to multiple markets and understands endorsement schedules is the most reliable way to find these carriers.
Purchase a buy-back where available. Some carriers will sell back the excluded coverage for an additional premium. The terms of buy-backs vary significantly — some restore the full subcontractor carve-back, others restore a more limited version. If a buy-back is available, the terms should be reviewed carefully before purchasing to confirm the restored coverage actually addresses the gap.
Strengthen your subcontractor agreement requirements. Requiring subcontractors to name you as an additional insured on their completed operations coverage — and verifying that their policy actually includes that endorsement rather than just accepting a certificate that claims it — ensures that their policy responds to completed operations claims arising from their work. This does not fix the gap in your own policy but it provides a secondary layer of protection.
Review your policy at every renewal. CG 22 94 is most often added quietly at renewal. Make reviewing the endorsement schedule a standard part of your renewal process — specifically looking for CG 22 94 or any proprietary endorsement with similar language about subcontractor work or completed operations exclusions. If it appears at renewal and was not on the prior policy, that is a conversation to have with your broker before accepting the renewal.
Frequently Asked Questions
How do I know if CG 22 94 is on my policy?
Look at the endorsement schedule in your CGL policy — typically the first few pages after the declarations page. Endorsements are listed by form number. If you see CG 22 94 or CG 22 94 10 01 (which refers to the October 2001 edition of the form) on that list, the exclusion is in your policy. Some carriers use proprietary endorsement numbers rather than the standard ISO form number — if you see any endorsement titled with language about subcontractor exclusion or damage to work performed by subcontractors, review it carefully or have your broker review it for you.
My sub has their own insurance. Why does CG 22 94 on my policy still matter?
Because your policy responds first when you are named in a claim regardless of who caused the damage. When a property owner sues the general contractor for a completed operations defect, your carrier receives the claim and makes a coverage determination. If CG 22 94 is on your policy, your carrier denies coverage and you are defending yourself out of pocket while you pursue the subcontractor's carrier separately. The subcontractor's insurance does not step in automatically just because the damage was caused by their work.
Can I add CG 22 94 back after my carrier has already excluded it?
In some cases yes — carriers who apply CG 22 94 will sometimes offer a buy-back endorsement for additional premium. However buy-backs are not universally available and the terms vary. In some states and markets no buy-back is offered at any price. If your carrier cannot or will not provide a buy-back, the most effective solution is moving to a carrier that does not apply the exclusion in the first place.
Does CG 22 94 affect my general liability limits or just my completed operations coverage?
CG 22 94 specifically targets the subcontractor carve-back within the completed operations coverage. Your general aggregate limit and per occurrence limit are not reduced — but those limits provide no protection for the claims CG 22 94 excludes. The practical effect is that a portion of the completed operations coverage you are paying for is unavailable for the type of claim most likely to arise from your operations as a GC.
What is the difference between CG 22 94 and CG 2294?
They are the same form written two different ways. CG 2294 is simply how many contractors type the form number when they are searching quickly — without the spaces. The full ISO format is CG 22 94. Both refer to the same endorsement this article covers. The confusion in Search Console data showing both terms is entirely a formatting difference, not two different forms.
I just got a certificate from my sub that lists me as additional insured. Does that protect me from CG 22 94?
No — and this is a critical point. Being listed as an additional insured on your subcontractor's policy means their policy may respond to certain claims involving their work. It does not affect how your own policy responds. CG 22 94 on your policy is a limitation of your own coverage. The subcontractor's additional insured endorsement and your own CG 22 94 exclusion operate independently. You need to address both — additional insured status on your sub's policy and removal of CG 22 94 from your own.
How common is CG 22 94 in contractor policies right now?
More common than most contractors realize. In the admitted market it varies by carrier and state — some carriers use it routinely on GC accounts, others reserve it for accounts with specific risk characteristics or loss histories. In the excess and surplus market it is significantly more prevalent. The best way to know whether it is in your policy is to look at the endorsement schedule rather than assume it is or is not there. If you have never specifically checked, checking at your next renewal is worthwhile.
This article is for general informational purposes only and does not constitute professional insurance or legal advice. Coverage availability, terms, and conditions vary by insurer, jurisdiction, and individual risk characteristics. Consult a licensed insurance professional for guidance specific to your operations.
Justin MacKenzie is a Commercial Account Executive at First West Insurance in Bozeman, Montana, specializing in insurance programs for contractors and construction businesses. He can be reached at justin@fstwest.com.
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