ISO GOVERNMENT CRIME COVERAGE FORMS AND POLICIES

(January 2026)

INTRODUCTION

The coverage provided by the Insurance Services Office (ISO) Government Crime Coverage Forms and Policies is similar to that provided by the ISO Commercial Crime Coverage Forms and Policies. This analysis addresses only the differences between them.

The following are the Government Crime Coverage Forms and Policies:

This analysis compares the CR 00 25–Government Crime Coverage Form (Loss Sustained Form) with the CR 00 21–Commercial Crime Coverage Form (Loss Sustained Form) and their Declarations.

Related Articles:

ISO Commercial Crime Coverage Forms and Policies Analysis

ISO Commercial Crime Coverage Forms and Policies Declarations

CR DS 03–CRIME AND FIDELITY COVERAGE PART DECLARATIONS (GOVERNMENT ENTITIES)

(0622 edition)

CR DS 03–Crime and Fidelity Coverage Part Declarations (Government Entities) differs from CR DS 01–Crime and Fidelity Coverage Part Declarations (Commercial Entities) in a single aspect. The new Fidelity Insuring Agreement provides two options for employee theft coverage: the named insured can choose either a per-loss basis or a per-employee basis.

CR 00 25–GOVERNMENT CRIME COVERAGE FORM (LOSS SUSTAINED FORM)

A. INSURING AGREEMENTS

(0622 edition)

In the 06 22 edition, all changes remain consistent. The only variation in coverage is the addition of employee theft-per-employee coverage in the Government Form. 

1. Fidelity

·         Employee Theft is renamed Employee Theft–Per Loss Coverage.

o   This coverage is identical to employee theft provided by the Commercial Crime Coverage Form.

·         Employee Theft–Per Employee Coverage is unique to the government crime coverage form.

o   Coverage is provided per employee, so the full insurance limit applies to each individual employee who commits a dishonest act, even if multiple employees are involved in the same loss.

·         ERISA is not applicable to Governments; therefore, coverage is not provided.

·         Forgery of Payment Card Instruments does not include ERISA plan officials.

Example: Meghan, Elizabeth, and John work in three different divisions of the city government. They think that their separation will prevent anyone from tracking their dishonest acts. However, an internal audit not only detects the loss of property but also traces the money back to them. The city’s total loss is estimated at $125,000.

Scenario 1: The city purchased $50,000 in employee theft-per loss coverage. It receives $50,000 because, despite three employees being involved, the incident is considered a single occurrence.

Scenario 2: The city purchased $50,000 employee-per employee coverage. The city receives $125,000 because each employee was covered for $50,000.

B. LIMIT OF INSURANCE

This section is identical in both coverage forms.

C. DEDUCTIBLE

This section is identical in both coverage forms.

D. EXCLUSIONS

(06 22 edition)

Exclusion 1.—Applicable to ALL insuring agreements

Only the subparagraphs listed below have been changed for the Government Crime Coverage Form:

a. Acts Committed by You replaces Acts Committed by You

The terms Partners or Members are excluded from this title because government entities do not have partners or members.

b. Acts Committed by Your  Employees, Officials, or Representatives

The terms ERISA Plan Officials, Managers, Trustees, or Representatives are excluded from this title since they do not apply to government entities. It substitutes “officials” for “ERISA plan officials, managers, trustees, or representatives.”

c. Acts Committed by Your Employees Prior to the Policy Period

ERISA Plan Officials has been removed from this title, since, as stated above, government entities are exempt from ERISA plans.

Exclusion 2.—Applicable to only insuring agreements A.1.a. and A.1.b.

(06 22 edition)

ERISA Employee Benefit Plans

This exclusion is removed from the government policy because ERISA does not apply to government entities.

Bonded Employees

This exclusion is added to the government policy. There is no coverage when a loss is caused by an employee who is required by law to be bonded.

NOTE: The exclusion applies whether the employee is actually bonded or not.

Treasurers or Tax Collectors

Coverage does not apply to any loss caused by an employee with treasurer or tax-collecting responsibilities. This exclusion applies even if the position is not identified as that of a treasurer or a tax collector.

Warehouse Receipts

Is removed because it does not apply to government entities.

Exclusion 3.—Applicable to only Insuring Agreements A.3., A.4., and A.5.

With the 6 22 edition, Transfer or Surrender of Property has been removed from both CR 00 21 and CR 00 25.

E. CONDITIONS

1. Conditions Applicable to ALL Insuring Agreements

Additional Premises or Employees

All references to consolidation, merger, purchase, or acquisition of another entity in the Commercial Crime Coverage Form have been removed. These are unnecessary because government entities do not participate in such activities.

Consolidation–Merger or Acquisition

This condition is omitted from the Government Crime Coverage Form since government entities do not engage in mergers or acquisitions.

Employee Benefits

With the 06 22 edition, this condition is now identical in each form.  

Extended Period to Discover Loss

The Government Crime Coverage Form does not incorporate the term termination, which was added to the CR 00 21 in the 06 22 edition. Additionally, it omits mention of ERISA, as it is not applicable to government entities.

Joint Insured

With the 06 22 edition, this condition is now identical in each form.

Valuation–Settlement

With the 06 22 edition, this condition is now identical in each form.  

2. Conditions Applicable to Insuring Agreements 1. and 2.

Indemnification

With the 06 22 edition, this condition has been removed from the government form.

Termination as to Any Employee

With the 06 22 edition, this condition has been removed from the government form.

4. Conditions Applicable to Insuring Agreements A.5.

Special Limit of Insurance for Specified Property

With the 06 22 edition, this condition has been removed from both CR 00 21 and CR 00 25.

F. DEFINITIONS

With the 06 22 edition, the numbers associated with each term in the Government Crime Form have been changed due to the addition of three terms.

7. Custodian

The Government Crime Coverage Form removes the terms partners and members.

11. Employee

The Government Crime Coverage Form substitutes “officials” for the phrase “partners, members, managers, officers, directors, or trustees” in the Commercial Crime Coverage Form. It also does not refer to mergers or acquisitions and does not include agents, brokers, factors, consignees, or commission merchant terms used in the Commercial Crime Coverage Form.

12. Employee benefit plan

With the 06 22 edition, this term has been added to the Government Crime Coverage Form. It excludes ERISA Employee benefit plans but includes any benefit plan not subject to ERISA.

12. Messenger

The Government Crime Coverage Form removes the terms insured relative, partners, or members.

14. Occurrence

(06 22 edition)

This definition is identical in both coverage forms. However, the Government Crime Coverage Form references different sections of Insuring Agreement A, as follows:

·         It adds a section for Insuring Agreement. A.1.b. Employee Theft–Per Employee. This slight change in this definition is very significant.

·         Under Insuring Agreement A.1a. Employee Theft—Per Loss Coverage, an occurrence includes the actions of all employees who act in collusion with others.

·         Under Insuring Agreement A.1.b.  Employee Theft—Per Employee Coverage, an occurrence includes the actions of each employee who acts in collusion with others.

·         It does not make reference to Employee Theft of Clients’ Property.

Example: Mary, Paula, and Frank work at a branch of the Bureau of Motor Vehicles. They plan to keep and evenly divide the proceeds from every tenth transaction. When Mary becomes ill and leaves, Paula and Frank suggest their scheme to her replacement. Instead of participating, she reports it to her supervisors. The total loss amounts to $300,000. The BMV occurrence limit is $100,000.

Scenario 1: Coverage is provided under Insuring Agreement A.1a. Employee Theft—Per Loss Coverage. There is only one occurrence, so the most the BMV can recover is $100,000.

Scenario 2: Coverage is provided under Insuring Agreement A.1.b. Employee Theft—Per Employee Coverage. Initially, there were three separate incidents involving three employees. Each incident is counted separately. The maximum payout for each case is either $100,000 or the amount stolen by that employee, whichever is less. If the stolen money was divided equally among the employees, the total payout could be $300,000.

20. Manager and 21. Member

Both of these terms are included in the Commercial Crime Coverage Form but not in the Government Crime Coverage Form, as they are not applicable to government entities.