Commercial General Liability Policies Explained (UK 2026)
What is a commercial general liability policy?
A commercial general liability (CGL) policy is a single liability policy that bundles a business's core third-party liability cover into one place — principally public liability and products liability. Rather than buying those covers separately, a CGL policy packages them under one schedule, with one set of limits and one renewal. For most trading businesses it is the foundation of their business liability insurance programme.
The term itself is borrowed from the United States, where "Commercial General Liability" is a defined, standardised policy form. In the UK market the phrase is used more loosely — it usually describes a combined public and products liability policy, sometimes extended with covers like financial loss or tenant's liability. That difference matters, because a business researching "CGL" online will find a lot of American material describing cover that does not map exactly onto a UK policy. This guide explains what a CGL policy means here: what it includes, what it quietly leaves out, and how to read one properly.
Miller & Partner approaches every placement through The Insurability Framework™ — a structured method covering underwriter intelligence, difficult-risk expertise, risk assessment and claims advocacy — and the same scrutiny applies to a CGL policy: not "do you have liability cover?" but "does this policy actually cover what your business does?"
Key facts about CGL policies at a glance
- A CGL policy bundles public liability and products liability into one policy with shared limits.
- The term is American in origin; in the UK it describes a combined liability policy rather than a single standardised form.
- Employers' Liability is NOT part of CGL — it is a separate, legally compulsory cover under the 1969 Act.
- Professional Indemnity is NOT part of CGL — claims about negligent advice or design need separate PI cover.
- Products liability usually carries an aggregate limit (an annual cap), while public liability is often per-occurrence.
- CGL is generally written on an occurrence basis — the policy in force when the incident happened responds.
- Standard exclusions (advice, own work, cyber, pollution, contractual liability) are where businesses most often find a gap.
What does "general liability" actually mean in the UK?
This is the question that causes the most confusion, so it is worth being precise. In the United States, a Commercial General Liability policy is a standardised form (the ISO CGL) covering bodily injury, property damage, and "personal and advertising injury" such as libel or slander. A UK reader searching "commercial general liability" will find that American definition first — and it does not match what a UK insurer will actually sell them.
In the UK, there is no single standardised "CGL form". Instead, "general liability" or "commercial general liability" is market shorthand for a combined public and products liability policy. Public liability covers injury or damage you cause to third parties; products liability covers harm caused by goods you supply once they are in someone else's hands. Packaging them together is convenient and usually cheaper than buying them apart — but the key point is what the package does not automatically include, which we come to below.
What's inside a typical CGL policy and what isn't?
The single most useful thing to understand about a CGL policy is the boundary between what comes inside the package and what you must arrange separately. This table is the heart of it.
| Cover | Inside a typical UK CGL policy? | Notes |
|---|---|---|
| Public Liability | Yes — core | Third-party injury and property damage from your activities. |
| Products Liability | Yes — core | Harm from goods you supply; usually an aggregate limit. |
| Employers' Liability | No — separate | Legally compulsory for employers under the 1969 Act. |
| Professional Indemnity | No — separate | Needed for negligent advice, design or services. |
| Own property / contract works | No | That is property or contractors' all-risks cover, not liability. |
| Cyber & data liability | Usually excluded | Needs standalone cyber cover. |
| The cost of your own faulty work | No | CGL covers resulting damage, not redoing the defective work itself. |
The pattern is clear: a CGL policy is a strong foundation for third-party injury and damage, but it is not "all my liability sorted." Employers' and professional liability sit outside it, and several common exposures are excluded. Our complete business liability guide shows how CGL fits alongside the other covers.
A business owner once told me, confidently, that he had "general liability, so I'm fully covered." He ran a small design-and-build firm. His CGL policy was perfectly good — public and products liability, sensible limits. But around half his work was design, and CGL does not touch professional negligence. The policy he was proud of would not have responded to his single biggest exposure. "General liability" sounds comprehensive precisely because of the word "general" — and that word is exactly where the false comfort lives. The skill is naming what the policy leaves out.
What does a CGL policy actually cover?
Within its two core sections, a CGL policy responds to your legal liability to pay damages to third parties, plus the legal costs of defending the claim. The main things it covers are:
- Third-party bodily injury — a member of the public or a customer injured because of your business activities or premises.
- Third-party property damage — damage you cause to property belonging to others while carrying out your work.
- Products liability — injury or damage caused by a product you have manufactured, supplied, repaired or sold, once it is in the customer's hands.
- Legal defence costs — the cost of defending a claim, which can be significant even when the claim ultimately fails.
Crucially, products liability is strict under the Consumer Protection Act 1987 — a claimant need not prove you were negligent, only that the product was defective and caused harm. That makes the products section of a CGL policy far more important than many businesses assume, including those who only resell or import goods.
What does a CGL policy NOT cover?
This is where the real value of understanding your policy lies. The most common — and most dangerous — exclusions and limitations on a UK CGL policy are:
- Professional negligence — claims that your advice, design or professional service was wrong. This needs professional indemnity.
- Employee injury — covered only by Employers' Liability, which is separate and legally compulsory.
- Your own faulty workmanship — CGL may cover damage that results from defective work, but not the cost of redoing the work itself.
- Cyber and data breaches — increasingly excluded; needs standalone cyber insurance.
- Pollution and contamination — often heavily limited or excluded.
- Contractual liability — liability you take on by contract beyond what the common law would impose may not be covered.
- Product recall and pure financial loss — the cost of recalling a product, or a client's financial loss without injury or damage, is generally outside CGL.
- Motor and own property — covered by motor and property policies respectively.
Because the word "general" implies breadth, CGL is the policy businesses most often over-rely on. It is excellent for what it does — third-party injury and damage — but it is not a substitute for employers' liability, professional indemnity or cyber cover. Read the exclusions before you assume a risk is covered.
How do limits and aggregates work on a CGL policy?
Two numbers govern how much a CGL policy will pay, and confusing them is a classic mistake. The limit of indemnity is the most the insurer will pay; it is commonly £1m, £2m, £5m or £10m depending on what your contracts demand. But how that limit applies differs by section:
- Public liability — usually "any one occurrence". The full limit is available for each separate claim, however many you have in a year.
- Products liability — usually "in the aggregate". The limit is the total the insurer will pay for all product claims across the whole policy year, not per claim.
That aggregate cap on products cover is easy to overlook and occasionally catastrophic — a manufacturer facing several product claims in one year can exhaust the aggregate and be left exposed on later claims. When you compare policies, check not just the headline limit but whether each section is per-occurrence or aggregate. If you are at the stage of comparing quotes side by side, that is the first thing to line up.
Is CGL on an occurrence or claims-made basis?
CGL is almost always written on an occurrence basis. That means the policy that responds is the one in force when the incident happened, not when the claim is eventually made — so a claim arriving years after a job is still covered by the policy that was live at the time of the incident. This is the opposite of professional indemnity, which is usually claims-made (the current policy responds regardless of when the work was done). Knowing which trigger applies tells you which year's policy to look to when a claim arrives, and why keeping records of past cover matters.
Interactive · CGL Cover Checker
What would a CGL policy cover for your business type?
Pick a business type to see what a CGL policy would handle for you — and, just as importantly, what it would leave you to arrange separately. Tags show how each cover is prioritised. A general guide to spot gaps, not advice on your own placement.
Tradesperson / contractor
Shop / retailer
Consultant / advisor
Café / hospitality
Manufacturer
Tech / online business
Do you actually need a standalone CGL policy?
For many businesses, the public and products liability cover that a CGL policy provides is bundled inside a wider commercial combined or package policy alongside property, business interruption and other sections. A standalone CGL policy makes most sense where liability is your main or only insurable exposure — a service business with little property, a contractor whose main risk is on third-party sites, or a business buying liability to satisfy a contract quickly.
The right structure depends on the whole risk, not just the liability piece. If you also need property, stock or interruption cover, a combined policy is usually simpler and better value; if liability is genuinely the core, a focused CGL policy can be the cleaner route. Our guides to business insurance for small business and the commercial insurance hub help you see where CGL fits.
Interactive · CGL Gap Awareness
Are you aware of the gaps a CGL policy leaves?
Tick each statement once you have confirmed how it applies to your business. A red box is an unconfirmed gap; a green tick means you have checked it. These are the eight gaps CGL most often leaves open.
- Employers' Liability is arranged separately if I have staff. CGL does not include it; it is legally compulsory.
- Professional Indemnity is in place if I advise or design. CGL excludes professional negligence entirely.
- I know the products section's aggregate limit. It caps all product claims in a year, not per claim.
- Cyber and data exposure is covered elsewhere. CGL increasingly excludes cyber and data claims.
- My limit meets my biggest contract's requirement. Check what each client and landlord demands.
- I understand it won't redo my own faulty work. It covers resulting damage, not the defective work itself.
- Contractual liabilities I've accepted are covered. Liability assumed by contract may fall outside cover.
- My business description covers every activity. Work outside the description is outside cover.
Interactive · CGL Fit Snapshot
Does a CGL policy fit your business, or do you need more?
Choose your situation for a quick indication of whether a CGL policy on its own is enough, or whether you need to add other covers around it.
What law sits behind a CGL policy?
A commercial general liability policy is a contract that responds to your legal liability — so understanding the law that creates that liability is what makes the cover meaningful. Three frameworks matter most.
Products liability and strict liability
The products section of a CGL policy responds to liability under the Consumer Protection Act 1987, which imposes strict liability for defective products. A claimant does not have to prove the business was negligent — only that the product was defective and caused injury or damage. Liability can attach to manufacturers, own-branders, importers and, where the supplier cannot identify who supplied them, retailers too. This is precisely why the products half of CGL matters even to businesses that only resell.
Why Employers' Liability sits outside CGL
Employee injury is deliberately excluded from CGL because it is governed by its own statute: the Employers' Liability (Compulsory Insurance) Act 1969 requires most employers to hold separate EL cover of at least £5 million, enforced by the HSE with penalties of up to £2,500 for each day uninsured. A CGL policy never satisfies that obligation — it is a separate purchase, and assuming "general liability" includes staff injury is a common and serious error.
The duty of fair presentation
Because CGL is commercial (non-consumer) insurance, the Insurance Act 2015 applies. You owe a duty of fair presentation — disclosing every material circumstance you know or ought to know when you arrange or vary the policy, clearly and accessibly. Describe your activities accurately and completely; a narrowed or careless business description is the fastest way to find a claim falling outside the very cover you bought, and can give the insurer a proportionate remedy that reduces the payout.
What drives the cost of a commercial general liability policy?
These are the levers an underwriter uses to price a CGL policy. The third column matters most — almost every factor can be influenced, which is how a well-presented business earns a lower premium without cutting cover.
| Rating factor | Why it moves the premium | How to mitigate it |
|---|---|---|
| Trade / activity | Sets the base hazard — high-risk work rates far above low-risk services. | Describe accurately; never over-broad, never narrowed to hide work. |
| Annual turnover | Proxy for the volume and size of potential third-party claims. | Declare honestly; split distinct activities so each is rated fairly. |
| Type of products supplied | Safety-critical, consumed or worn products raise the products-liability rate. | Evidence quality control, testing and supplier vetting. |
| Limit of indemnity | Higher limits increase the insurer's maximum exposure. | Match the limit to your contracts — adequate, not excessive. |
| Products aggregate | A higher annual products cap costs more but protects against multiple claims. | Set it realistically against how many product claims a bad year could bring. |
| Public footfall / contact | More interaction with the public raises injury frequency. | Document safety procedures, signage and incident logs. |
| Claims history | Past frequency and severity predict future losses. | Provide context and evidence of remedial action. |
| Sub-contractor use | Work by others can expose you to vicarious liability. | Require their own cover; keep certificates and written terms. |
| Geographic scope | Supplying to higher-litigation territories (e.g. North America) raises product rates sharply. | Declare export markets; exclude territories you don't trade in. |
| Premises & working environment | Reflects local risk and the hazards of where you work. | Maintain premises; provide risk assessments. |
| Excess level | A higher voluntary excess transfers small-claim cost to you, lowering premium. | Set an excess you can comfortably fund on each claim. |
| Risk management evidence | Documented procedures reduce the underwriter's uncertainty. | Supply risk assessments, method statements and training records. |
What do real claims teach us about CGL cover?
Three anonymised but representative claims show how the boundaries of a CGL policy — what is in, what is out, and how the limits apply — decided each outcome.
Maesteg Shopfitters — the claim CGL paid in full
A shopfitting firm dislodged a heavy display unit during an installation; it fell and injured a customer in the client's store. This is textbook third-party bodily injury — exactly what the public liability section of a CGL policy is built for. The firm held a £5m CGL policy, and the claim and defence costs were met in full.
Cwmbran Components — the exhausted aggregate
A parts manufacturer supplied a batch with a latent defect. Multiple customers suffered damage, producing a cluster of product claims in a single policy year. The CGL limit was £2m — but products liability was written "in the aggregate", so £2m was the total available for all product claims that year, not per claim. The later claims hit an exhausted limit.
Penarth Design & Build — the gap CGL didn't cover
A design-and-build contractor believed its CGL policy covered "everything liability". A structural element it had designed failed, and the client claimed for the cost of redesign and remedial works, alleging negligent design. CGL covers third-party injury and damage — but not professional negligence. The design allegation fell outside the policy, and there was no separate professional indemnity in place.
How should you handle a CGL claim, step by step?
A liability claim under a CGL policy is where the cover is tested. Handling it well protects both your settlement and your future insurability. Follow these eight steps.
-
Make people safe and record the scene
Attend to anyone injured first, then photograph the location, the product or work involved, and the conditions before anything is moved.
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Notify your broker or insurer immediately
Report any incident that might lead to a claim without delay — CGL policies require prompt notification, and late reporting can prejudice cover.
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Do not admit liability
Be courteous and factual, but never accept blame or promise payment; admitting liability can breach the policy and undermine the insurer's defence.
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Preserve the product and all evidence
Keep the item involved, batch records, quality-control logs, risk assessments and witness details — these often decide a public or products claim.
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Identify which section and year responds
Establish whether it is a public or products claim, and which policy year covers it, since CGL is occurrence-based and aggregates apply per year.
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Pass on any correspondence unanswered
Forward letters of claim, solicitor letters and court documents to your insurer straight away — do not respond to them yourself.
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Cooperate with the insurer's investigation
Work with the appointed adjuster or solicitor and provide what they ask for promptly; the insurer controls the defence under the policy.
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Review limits, aggregates and gaps afterwards
After a claim, reassess your limit, the products aggregate and any covers sitting outside the CGL policy, so the same exposure is fully protected next time.
John Miller
Director & Principal Broker — Miller & Partner
John has spent 13+ years placing commercial liability cover for UK businesses, with direct access to the Lloyd's Market and specialist MGA schemes. A former #1 Account Executive at Brown & Brown and #1 Salesperson at AXA, he spends much of his week doing exactly what this guide describes — reading CGL schedules section by section, checking aggregates and exclusions, and making sure "general liability" is backed by the specific covers a business actually needs.
Miller & Partner Limited is an Appointed Representative of Gauntlet Risk Management Ltd, which is authorised and regulated by the Financial Conduct Authority. Miller & Partner Limited is registered in England and Wales and trades from Vivian House, Roman Bridge Close, Mumbles, Swansea SA3 5BG.
This guide is general information about how commercial general liability policies work in the UK. It is not advice on your own insurance arrangements — cover, limits and exclusions vary between insurers and policy wordings, so always read your own schedule and speak to a broker about your specific risk.
Commercial general liability glossary
- Commercial General Liability (CGL)
- A combined liability policy bundling public and products liability under one schedule; the term originates in the US market.
- Public Liability
- Cover for your legal liability for injury to a third party or damage to their property caused by your business.
- Products Liability
- Cover for harm caused by a product you supplied, manufactured, repaired or sold, once it is in someone else's hands.
- Third party
- Anyone outside your business who suffers harm — a customer, visitor or member of the public.
- Limit of indemnity
- The maximum the insurer will pay; commonly £1m, £2m, £5m or £10m on a CGL policy.
- Any one occurrence
- A limit basis where the full amount is available for each separate claim — usual for the public liability section.
- In the aggregate
- A limit basis where the amount is the total for all claims in a policy year — usual for the products section.
- Occurrence basis
- Cover triggered by when the incident happened; the policy then in force responds. Standard for CGL.
- Claims-made basis
- Cover triggered by when the claim is made; the current policy responds. Used for professional indemnity, not CGL.
- Strict liability
- Liability that applies without proving negligence — as under the Consumer Protection Act 1987 for defective products.
- Vicarious liability
- Your responsibility for acts of employees, and sometimes sub-contractors, carried out for your business.
- Exclusion
- A risk the policy specifically does not cover, such as professional negligence, cyber or employee injury under CGL.
- Duty of fair presentation
- The legal duty under the Insurance Act 2015 to disclose all material circumstances when arranging commercial cover.
- Commercial combined
- A wider package policy that often contains CGL-type liability alongside property, stock and business interruption.
- Excess
- The first part of any claim you pay yourself; a higher excess lowers the premium.
Commercial general liability — frequently asked questions
What is a commercial general liability policy?
It is a single policy that bundles a business's core third-party liability covers — principally public liability and products liability — under one schedule and one set of limits. The term comes from the US market; in the UK it describes a combined public and products liability policy.
Is commercial general liability the same as public liability?
Not quite. Public liability is one part of a CGL policy. CGL also includes products liability, so it is broader than public liability alone — but it still excludes employers' liability and professional indemnity, which are separate covers.
Does a CGL policy include employers' liability?
No. Employers' Liability is a separate, legally compulsory cover under the 1969 Act, with a £5 million minimum. A CGL policy never satisfies that obligation, so any business with staff must arrange EL separately.
Does CGL cover professional advice or design?
No. Claims that your advice, design or professional service was negligent are excluded from CGL and need professional indemnity insurance. This is the single most common gap for design-and-build, consultancy and service businesses that assume "general" means everything.
What does a CGL policy actually cover?
It covers your legal liability for third-party bodily injury and property damage arising from your activities (public liability), and harm caused by products you supply (products liability), plus the legal costs of defending those claims. It responds to claims from third parties, not to your own losses.
What does a CGL policy not cover?
Common exclusions include professional negligence, employee injury (employers' liability), the cost of redoing your own faulty work, cyber and data breaches, pollution, product recall, pure financial loss, and motor and own-property risks. Always read the exclusions before assuming a risk is covered.
What is the difference between per-occurrence and aggregate limits?
"Any one occurrence" means the full limit is available for each separate claim — usual for public liability. "In the aggregate" means the limit is the total for all claims in a policy year — usual for products liability. A cluster of product claims can exhaust an aggregate, so check which basis applies to each section.
Is CGL written on an occurrence or claims-made basis?
CGL is almost always occurrence-based, meaning the policy in force when the incident happened responds, even if the claim arrives years later. This differs from professional indemnity, which is usually claims-made and triggered by when the claim is made.
How much CGL cover do I need?
The limit depends on what your contracts and clients require — commonly £1m, £2m or £5m — and on the scale of loss a claim could cause. Manufacturers should also size the products aggregate against a realistic bad-year scenario, not a single claim. Match the limit to your real exposure rather than picking the lowest.
Is a standalone CGL policy or a combined policy better?
It depends on the whole risk. If liability is your main or only insurable exposure, a focused CGL policy can be the cleaner route. If you also need property, stock or business interruption cover, a commercial combined policy that contains the liability sections is usually simpler and better value.
Do I have to disclose everything when arranging CGL cover?
Yes. As commercial insurance, CGL is subject to the Insurance Act 2015 duty of fair presentation — you must disclose every material circumstance you know or ought to know, clearly, and describe your activities accurately. A narrowed or careless description can leave a claim outside cover and give the insurer a proportionate remedy.
Can I get CGL cover if I've been declined or have claims?
Yes. A previous declinature or claims history makes a risk non-standard, not uninsurable. Miller & Partner approaches every placement through The Insurability Framework — covering underwriter intelligence, difficult-risk expertise, risk assessment and claims advocacy — and uses specialist Lloyd's and MGA markets to place risks the standard engines decline.
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