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UST | FR | Insurance Requirements

UST Financial Responsibility (FR)

Commercial Liability Insurance Requirements at a Glance

Revised On: Dec. 6, 2023 - 6:00 p.m.

Insurance is the most common financial responsibility (FR) mechanism to demonstrate FR for underground storage tanks (USTs). Here are a few key concepts to keep in mind when submitting UST pollution liability insurance for FR via myDEQ:

A Certificate of Insurance and full policy1 are required for FR compliance. 

The Certificate of Insurance has:

Example of a Certificate of Insurance | View/Download >

The full policy has:

  • A declarations page
  • Insuring agreements/conditions
  • Definitions
  • Exclusions

Request a copy of your full policy from your insurance and follow up to help ensure you receive it before your current FR expires | View/Download Example of a Full Policy >

Other considerations:

  • Submit FR documentation via myDEQ | Learn More & Register >
  • Check the expiration date to ensure the insurance policy is current.
  • When the policy is renewed and/or changed, submit a copy of the insurance policy to ADEQ via myDEQ.
  • The name on the policy or additional insured must match either the name of the owner or the name of the operator of the facility. If the owner/operator is a company name, the entity must match our records exactly.
  • Make sure the submission includes a tank schedule (typically included on the policy) and a retroactive date.
  • Even if a retroactive date predates the insured's ownership of the UST, the retroactive date must be included in documentation. If the insurance carrier will not backdate the retroactive date, consider providing the date of the most recent baseline assessment or comparable site characterization | Learn More About Retroactive Date Requirements >

ACORDs, Declarations and Binders are NOT acceptable documentation of FR compliance.


ACORDs do not have:

  • A tank schedule
  • The required language
  • A signature

An ACORD can be identified by the “ACORD” logo on the upper-left corner of the document and the “CERTIFICATE OF LIABILITY INSURANCE” title on the top of the document | View/Download Example of an ACORD >


Declarations provide an overview of basic policy information and do not provide:

  • A tank schedule
  • The required language
  • A signature (sometimes)

This document can be identified by looking for the word “Declarations” | View/Download Examples of Declarations >

Exceptions: Please note that a few Tank Schedules are entitled as “Declaratons” and this document is submitted with the Certificate of Insurance or Endorsement.


A binder is a contract of temporary insurance pending the issuance of a formal policy or proper rejection of the application by the insurer. Binders are typically incomplete and typically mean the premium is still do. They do not provide:

  • The required language
  • A signature (sometimes)

Binder Examples | View/Download >

1 The full policy is required per the 2018 EPA memo, Underground Storage Tank Insurance Policies – Voluntary Exclusions and Self-Insured Retentions | View Memo >