On a federal contract, the prime carries the government's insurance obligations — and then passes them down to you. Those "flow-down" clauses in your subcontract decide what you must carry, and getting them wrong stalls your onboarding and your first payment.
What a flow-down clause actually is
A flow-down (or "conduit") clause obligates you, the subcontractor, to meet the same terms the prime owes the government — including insurance. When the prime's contract references FAR 52.228 or agency-specific requirements, those requirements become yours by reference, even if the dollar limits aren't spelled out in your subcontract.
The coverages primes commonly require
- General liability at specified per-occurrence and aggregate limits.
- Workers' compensation — often with the Defense Base Act extension on overseas work.
- Commercial auto for any vehicles used in performance.
- Professional and cyber where the scope involves design, IT, or controlled unclassified information.
Why COIs get rejected: the most common reasons are missing additional insured status for the prime and the government, a missing waiver of subrogation, or limits that don't match the flow-down. A certificate that doesn't mirror the clause exactly gets bounced — and your start date slips.
Read the flow-down before you sign
Because flow-downs incorporate requirements by reference, the real obligations often aren't visible in your subcontract's plain text. Have the insurance clauses reviewed against your actual policies before signing, not after the prime's compliance team rejects your COI. For the full framework, see our pillar guide to federal contractor insurance and FAR 52.228.
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