ACORD 28: Evidence of Property Insurance Explained
By SmartCOI Team
What Is the ACORD 28 Form?
The ACORD 28 is the standard Evidence of Commercial Property Insurance form used across the U.S. insurance industry. While most property managers are familiar with the ACORD 25 — the Certificate of Liability Insurance — the ACORD 28 serves a different and equally important purpose. It provides evidence that a party carries commercial property insurance covering physical assets like buildings, contents, and business income.
ACORD (Association for Cooperative Operations Research and Development) publishes both forms as part of its standardized insurance documentation system. The ACORD 28 specifically summarizes property-related coverages: what physical assets are insured, for how much, under what conditions, and who has a financial interest in the property.
If you manage commercial properties and require tenants to carry property insurance on their leased space, tenant improvements, and business contents, the ACORD 28 is the document you should be requesting. It is the property-side counterpart to the liability-focused ACORD 25.
When and Why the ACORD 28 Is Used
The ACORD 28 comes into play whenever someone needs to verify that commercial property insurance is in place. Unlike the ACORD 25, which documents liability coverage (general liability, auto, workers' comp, umbrella), the ACORD 28 documents coverage for physical property and related financial losses.
Tenant lease compliance. Commercial leases almost always require tenants to insure their own contents, tenant improvements, and sometimes business income. The ACORD 28 provides evidence that these coverages exist and meet lease requirements.
Lender and mortgagee requirements. When a property is financed, the lender needs evidence that the building is insured. The ACORD 28 documents the property insurance policy details — building coverage amount, deductibles, special conditions — and identifies the lender as a loss payee or mortgagee.
Property transactions. During acquisitions, refinancing, or lease negotiations, parties need to verify property insurance details quickly. The ACORD 28 serves as a standardized summary that avoids the need to review the full policy document.
Landlord verification. Property owners and managers use the ACORD 28 to confirm that tenants carry adequate property coverage. If a tenant's space is damaged by a fire they caused, the tenant's property insurance should cover their own losses — not the landlord's policy.
ACORD 28 vs ACORD 25: Key Differences
This is the most common source of confusion in COI management. Both forms are issued by insurance agents to provide evidence of coverage, but they document fundamentally different types of insurance.
| | ACORD 25 | ACORD 28 | |---|---|---| | Full name | Certificate of Liability Insurance | Evidence of Commercial Property Insurance | | Coverage type | Liability (GL, auto, WC, umbrella) | Property (building, contents, business income) | | What it protects | Against claims from third-party injuries and damage | Physical assets and financial losses from property damage | | Common coverages listed | General liability, auto liability, workers' comp, umbrella/excess | Building, business personal property, business income, equipment breakdown | | Key limits | Per occurrence, general aggregate, CSL | Building value, contents value, business income limit | | Who requests it | Property managers verifying vendor/tenant liability coverage | Lenders, mortgagees, landlords verifying property coverage | | Loss payee / mortgagee | Not applicable | Listed on the form — identifies parties with financial interest | | Additional insured | Listed in Description of Operations | May be listed but less common than on ACORD 25 | | Most common use | Vendor and contractor compliance | Tenant property insurance and lender requirements |
The simple rule: If you need to verify that someone has coverage for claims and lawsuits (someone gets hurt, something gets damaged by their negligence), request an ACORD 25. If you need to verify that someone has coverage for their own physical property and assets, request an ACORD 28.
For many tenant relationships, you need both. The ACORD 25 confirms the tenant carries liability coverage protecting you against claims arising from their operations. The ACORD 28 confirms the tenant insures their own space, contents, and business income — so their losses do not become your problem.
Key Fields on the ACORD 28 Form
Understanding the ACORD 28's layout helps you review it efficiently and catch compliance gaps.
Named insured
The entity that purchased the property insurance policy. For tenant compliance, this should match the tenant's legal entity name in your lease. If the lease is with "Downtown Café LLC" but the ACORD 28 shows "Downtown Café, Inc.," investigate the discrepancy before accepting the certificate.
Property description and location
The ACORD 28 describes the specific property being insured, including the address and a description of the building or space. For tenant compliance, verify that the property address matches the leased premises. A tenant with multiple locations may have a policy covering a different property — the ACORD 28 should reference the specific location in your building.
Coverage types
The ACORD 28 lists several property coverage categories:
Building coverage. Covers the physical structure. For tenants, this typically applies to tenant improvements and betterments — the modifications the tenant made to the leased space (built-out offices, installed kitchen equipment, custom flooring). The building coverage amount should reflect the replacement cost of these improvements.
Business personal property (contents). Covers the tenant's movable assets — furniture, equipment, inventory, fixtures. Most leases require tenants to insure their contents at replacement cost.
Business income / extra expense. Covers lost income and additional expenses if the tenant cannot operate due to a covered property loss. If a fire forces a restaurant tenant to close for three months, business income coverage pays for the lost revenue and ongoing expenses during restoration. This coverage protects the tenant's ability to continue paying rent.
Equipment breakdown. Covers mechanical and electrical equipment failures — HVAC systems, boilers, electrical panels. This is separate from standard property coverage, which typically excludes equipment breakdown.
Policy limits and deductibles
Each coverage type shows the insured amount and the deductible. Review both:
- Insured amount. Does the building/contents coverage meet the minimum required by the lease? A tenant with $50,000 in contents coverage but $200,000 worth of equipment is underinsured.
- Deductible. High deductibles may leave the tenant unable to pay for smaller losses. Some leases cap the allowable deductible.
Valuation method
The form indicates whether coverage is on a replacement cost or actual cash value (ACV) basis. Replacement cost pays to replace or repair damaged property at current prices. ACV deducts depreciation. Replacement cost is preferred because it provides adequate funds for full restoration. If your lease requires replacement cost coverage, verify this field.
Loss payee / mortgagee information
This is a field unique to the ACORD 28 (the ACORD 25 does not have it). A loss payee is a party with a financial interest in the insured property who is entitled to receive insurance proceeds in the event of a loss. Common loss payees include:
- Mortgage lenders — listed as mortgagee, they receive proceeds to protect their loan collateral
- Landlords — may be listed as loss payee for tenant improvements that revert to the landlord
- Equipment lessors — listed as loss payee on leased equipment
Verify that the loss payee information matches your requirements. If your lease requires the property owner to be listed as loss payee on the tenant's property insurance, confirm the correct entity name appears.
Additional insured
While additional insured status is more commonly associated with the ACORD 25 (liability coverage), it can also appear on the ACORD 28. Being listed as an additional insured on a property policy is less common but may be required in certain lease structures.
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Try SmartCOI FreeWho Requests ACORD 28 Forms and Why
Several parties routinely request ACORD 28 certificates, each for different reasons.
Mortgage lenders. Banks and lending institutions require ACORD 28 forms as evidence that financed properties are adequately insured. The lender is typically listed as mortgagee so they are notified of any policy changes and receive proceeds if the property is destroyed.
Property owners and landlords. Owners request ACORD 28 forms from tenants to verify that tenant improvements, contents, and business income are insured. If a tenant's negligence causes a fire that destroys their own space, the tenant's property insurance — not the landlord's — should respond.
Property managers. As agents for property owners, property managers collect and track ACORD 28 forms as part of tenant compliance programs. This is especially important in multi-tenant commercial properties where one tenant's uninsured loss can disrupt the entire building.
Loss payees. Equipment lessors, franchise companies, and other parties with financial interests in the insured property may require ACORD 28 forms to confirm their loss payee status.
How Property Managers Use ACORD 28 Forms for Tenant Compliance
For property managers overseeing commercial portfolios, the ACORD 28 is a critical piece of the tenant insurance compliance puzzle. Here is how it fits into a comprehensive tracking program.
Requiring both ACORD 25 and ACORD 28 from tenants
Best practice for commercial tenants is to require both forms:
- ACORD 25 — confirms general liability, covering claims from injuries or property damage caused by the tenant's operations
- ACORD 28 — confirms property insurance, covering the tenant's own space, contents, and business income
A tenant might have excellent liability coverage (ACORD 25) but no property insurance (ACORD 28). If a fire destroys their tenant improvements and inventory, they have no coverage to rebuild — which means they cannot reopen, which means they cannot pay rent.
Setting clear lease requirements
Your lease should specify the property insurance requirements that the ACORD 28 must evidence:
- Minimum coverage amounts for tenant improvements and contents
- Business income coverage for a specified period (typically 12 months)
- Replacement cost valuation (not actual cash value)
- Property owner listed as loss payee or additional insured
- Maximum allowable deductible
Tracking ACORD 28 expirations alongside ACORD 25
Property insurance policies expire just like liability policies. A robust expiration tracking system should monitor both forms, sending renewal reminders well before coverage lapses.
Automated extraction and compliance checking
Manually reviewing ACORD 28 forms presents the same challenges as reviewing ACORD 25 forms — it is time-consuming, error-prone, and does not scale. AI-powered extraction can read ACORD 28 forms just as effectively as ACORD 25 forms, pulling coverage amounts, deductibles, valuation methods, loss payee information, and policy dates automatically.
Common Mistakes When Reviewing ACORD 28 Certificates
Accepting ACORD 25 when ACORD 28 is required
The most fundamental error. A tenant provides an ACORD 25 showing general liability coverage, and the property manager files it as proof of insurance compliance. But the lease requires property insurance, which only appears on the ACORD 28. Liability coverage and property coverage are completely different — having one does not satisfy the requirement for the other.
Not verifying the property address
An ACORD 28 may be legitimate but cover a different location. If the tenant operates at multiple sites, ensure the certificate references the specific property in your building. Coverage for their warehouse across town does not protect the improvements in your space.
Ignoring the valuation method
The difference between replacement cost and actual cash value can be enormous. A ten-year-old tenant buildout that cost $300,000 might have an ACV of only $100,000 after depreciation. If replacement cost is $350,000, ACV coverage leaves a $250,000 gap.
Overlooking business income coverage
Tenants often insure their physical property but skip business income coverage. Without it, a major loss can force the tenant to close permanently — meaning no rent revenue for the landlord during the vacancy period. This coverage protects both the tenant and the landlord's income stream.
Not checking the loss payee
If the lease requires the property owner to be listed as loss payee, verify this on every ACORD 28 renewal. Loss payee status ensures the landlord is notified of policy changes and receives proceeds when the tenant's property insurance pays a claim on improvements that belong to or revert to the landlord.
Missing the deductible
A tenant with $500,000 in contents coverage but a $100,000 deductible may not file a claim for smaller losses. If your lease specifies a maximum deductible, check this field on every ACORD 28 you receive.
Frequently Asked Questions
What is the difference between ACORD 25 and ACORD 28?
The ACORD 25 is the Certificate of Liability Insurance — it documents coverage for claims and lawsuits (general liability, auto liability, workers' compensation, umbrella). The ACORD 28 is the Evidence of Commercial Property Insurance — it documents coverage for physical assets and financial losses (building, contents, business income, equipment breakdown). Property managers typically need the ACORD 25 from vendors and contractors and both the ACORD 25 and ACORD 28 from tenants.
Who fills out the ACORD 28 form?
The ACORD 28 is completed by the insurance agent or broker who issued the property insurance policy. The insured party (tenant, property owner, or borrower) requests the form from their agent, who then generates it from their certificate management system. The insured does not fill out the form themselves — it is always issued by a licensed insurance professional.
Is ACORD 28 the same as evidence of property insurance?
Yes. The ACORD 28 form is officially titled "Evidence of Commercial Property Insurance." It is the industry-standard document for providing proof that commercial property insurance exists. When a lender, landlord, or property manager requests "evidence of property insurance," the ACORD 28 is the expected response.
When should I request an ACORD 28 vs ACORD 25?
Request an ACORD 25 when you need to verify liability coverage — this applies to vendors, contractors, and tenants. Request an ACORD 28 when you need to verify property coverage — this typically applies to tenants (for their contents and improvements) and to borrowers (for the financed property). For commercial tenants, best practice is to request both forms to verify both liability and property coverage.
Does the ACORD 28 replace the need for an ACORD 25?
No. The two forms cover entirely different types of insurance. An ACORD 28 shows property coverage (building, contents, business income), while an ACORD 25 shows liability coverage (general liability, auto, workers' comp). A tenant can be fully compliant on property insurance (ACORD 28) while completely lacking general liability coverage (ACORD 25). Both forms are needed for comprehensive compliance verification.
Key Takeaways
The ACORD 28 is the property-side complement to the ACORD 25. For property managers running tenant compliance programs, understanding both forms is essential.
- The ACORD 28 documents property insurance — building coverage, contents, business income, equipment breakdown
- The ACORD 25 documents liability insurance — general liability, auto, workers' comp, umbrella
- For tenants, require both forms to verify comprehensive coverage
- Always verify the property address, valuation method, loss payee, and deductible on every ACORD 28
- Track ACORD 28 expirations with the same rigor as ACORD 25 expirations
- AI-powered extraction handles both ACORD 25 and ACORD 28 forms, eliminating manual review
Whether you manage a single building with ten tenants or a portfolio of fifty properties, getting ACORD 28 compliance right protects your tenants, your owners, and your management company from preventable losses.