CGL Insurance Malaysia | Comprehensive General Liability
Third-party liability protection for contractors, manufacturers, and industrial operations. Covers bodily injury, property damage, and products liability arising from your business activities.
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Your CAR policy covers damage to the works. Your IAR covers your factory property. Your workmen compensation covers your workers. But what covers the delivery driver injured by debris from your construction site? Or the neighbouring factory damaged by your chemical spill? Or the end-user harmed by your manufactured product?
That's CGL: Comprehensive General Liability. It covers third-party bodily injury, property damage, and products liability arising from your business operations. For contractors and manufacturers, it's the liability layer that completes your P&E insurance programme.
This guide covers:
- What CGL covers for industrial and construction operations
- CGL vs CAR Section II vs WC vs SPPI comparison
- When Malaysian contracts mandate CGL
- Premium factors for contractors and manufacturers
- Standard exclusions and what fills the gaps
- Industrial claim scenarios
- How CGL fits your P&E programme
What CGL Insurance Covers
CGL is an occurrence-based policy. It covers claims arising from incidents that occur during the policy period, regardless of when the claim is filed. This is different from claims-made policies like SPPI, where the claim must be made during the policy period.
CGL Coverage Components
| Coverage Section | What It Covers | Industrial / Construction Example |
|---|---|---|
| Bodily injury to third parties | Physical injury, illness, or death of non-employees caused by your operations | Pedestrian injured by falling debris from construction site. Visitor slips on factory floor. |
| Property damage to third parties | Physical damage to property you don't own or control, caused by your operations | Piling work cracks adjacent building foundation. Chemical leak contaminates neighbouring premises. |
| Products liability | Injury or damage caused by products you manufacture, sell, or distribute after they leave your premises | Fabricated steel component fails at client's site. Packaged food product causes illness. |
| Completed operations | Damage or injury caused by work you've already finished and handed over | M&E installation leaks 6 months after handover. Structural work shows defects after completion. |
| Legal defence costs | Lawyer fees, court costs, and investigation expenses for defending against covered claims | Defending a RM2M claim from a chemical spill affecting nearby residents |
| Medical expenses | Immediate medical treatment for injured third parties, regardless of fault determination | First aid and hospital fees for an injured site visitor before liability is determined |
CGL vs Other Liability Coverages
Contractors and manufacturers often have multiple liability coverages across different policies. Understanding what each one covers prevents both gaps and overlaps.
| Feature | CGL | CAR Section II | WC / SOCSO | SPPI |
|---|---|---|---|---|
| Who it protects | Third parties (non-employees, public, other businesses) | Third parties near the project site | Your workers | Your client (professional negligence) |
| Scope | All business operations, all locations, all projects | Specific insured project site only | Workplace injuries | Specific insured project only |
| Trigger basis | Occurrence-based | Occurrence within project period | Occurrence (workplace accident) | Claims-made |
| Products liability | Yes (standard extension) | No | No | No (design defect only) |
| Completed operations | Yes | Only during maintenance period | No | Yes (professional scope) |
| Off-site coverage | Yes (all business locations) | No (project site only) | Commute only (SOCSO) | No (project only) |
| Employee injuries | No (excluded) | No | Yes (primary purpose) | No |
The key distinction: CAR Section II only covers third-party liability at the specific project site. Once your crew moves to a different site, finishes the project, or causes damage away from the insured project, CAR Section II doesn't apply. CGL covers your operations everywhere, all the time.
For contractors running multiple projects simultaneously, CGL provides the blanket liability coverage that project-specific CAR policies can't.
When Malaysian Contracts Require CGL
CGL is not legally mandatory in Malaysia. But contractual requirements effectively make it mandatory for most industrial and construction operations.
| Contract Type | Typical CGL Requirement | Minimum Limit Usually Required |
|---|---|---|
| JKR / government construction projects | Mandatory, specified in tender conditions | RM1M - RM5M per occurrence |
| PETRONAS vendor registration | Mandatory for all PETRONAS contractors | RM5M - RM10M per occurrence |
| Private developer construction | Usually required, varies by developer | RM2M - RM5M per occurrence |
| Manufacturing supply chain (MNC) | Required for vendor qualification | RM2M - RM10M per occurrence |
| Data centre construction | Mandatory, high limits due to surrounding equipment value | RM5M - RM20M per occurrence |
| Subcontractor agreements | Main contractors often require subcontractor CGL | RM1M - RM5M per occurrence |
| Factory tenant lease agreements | Landlord requires tenant CGL for operations liability | RM1M - RM2M per occurrence |
If you're a contractor bidding on government or large private projects, you'll need CGL before you can mobilise. Many contractors discover this requirement at the last minute during site mobilisation. Having an annual CGL policy already in place means you don't have to scramble for coverage when a new project starts.
CGL Coverage Limits for Industrial Operations
The right CGL limit depends on the nature of your operations and contractual requirements. Underinsuring can leave you personally exposed for amounts above your policy limit.
| Business Profile | Annual Turnover | Recommended Limit | Key Risk Drivers |
|---|---|---|---|
| Small contractor (CIDB G1-G3) | Under RM5M | RM1M - RM2M | Site access, manual labour, small tools |
| Medium contractor (CIDB G4-G5) | RM5M - RM30M | RM2M - RM5M | Heavier equipment, more workers, subcontractor management |
| Large contractor (CIDB G6-G7) | RM30M+ | RM5M - RM10M | High-rise, infrastructure, complex sites, public exposure |
| M&E subcontractor | RM5M - RM50M | RM2M - RM5M | Working near existing installations, water/fire risks |
| Small-medium manufacturer | RM5M - RM30M | RM1M - RM3M | Factory visitors, delivery access, product liability |
| Large manufacturer / exporter | RM30M+ | RM5M - RM10M | Products liability exposure, MNC supply chain requirements |
| O&G contractor / vendor | Varies | RM10M - RM25M | PETRONAS requirements, hazardous environment, high consequence |
Get a CGL quotation tailored to your operations and contract requirements
Premium Factors for Industrial CGL
CGL premiums are non-tariff in Malaysia. Rates are negotiated between broker and underwriter based on your specific risk profile. A broker who understands industrial operations can present your risk in a way that earns better terms.
| Factor | Impact on Premium | What Underwriters Assess |
|---|---|---|
| Annual turnover | Primary rating factor. Higher turnover = more exposure = higher premium. | Audited financial statements, revenue breakdown by activity |
| Industry classification | Construction and chemical operations attract higher rates than general manufacturing. | Nature of operations, hazard profile, work environment |
| Claims history | 3-5 year loss record. Frequency matters more than severity for renewal pricing. | Number of claims, total paid, open reserves, root causes |
| Safety management | Strong safety record can reduce rates by 10-25%. | OHSAS/ISO 45001, HIRARC, safety training records, incident frequency rate |
| Limit of liability | Doubling the limit does not double the premium. Incremental cost decreases at higher limits. | Per occurrence limit, aggregate limit, sublimits |
| Products liability exposure | Manufacturers with products entering the supply chain face additional loading. | Product types, distribution channels, export markets, QC processes |
| Deductible | Higher deductible = lower premium. Construction deductibles typically RM5,000-25,000. | Risk retention appetite, cash flow capacity |
| Workforce size and composition | More workers = more exposure opportunities. Foreign worker percentage also considered. | Total headcount, skill level, training certification |
Indicative CGL Premium Ranges
| Business Type | CGL Limit | Indicative Annual Premium |
|---|---|---|
| Small contractor, RM5M turnover | RM1M per occurrence | RM2,500 - RM5,000 |
| Medium contractor, RM20M turnover | RM3M per occurrence | RM8,000 - RM15,000 |
| Large contractor, RM50M+ turnover | RM5M per occurrence | RM15,000 - RM35,000 |
| M&E subcontractor, RM15M turnover | RM2M per occurrence | RM5,000 - RM12,000 |
| General manufacturer, RM20M turnover | RM2M per occurrence | RM4,000 - RM10,000 |
| Chemical manufacturer, RM30M turnover | RM5M per occurrence | RM20,000 - RM45,000 |
| O&G contractor/vendor | RM10M per occurrence | RM25,000 - RM80,000 |
CGL is one of the most affordable industrial insurance products relative to the protection it provides. For a medium-sized contractor, the premium is often less than one month's salary of a single worker, but it protects against multi-million ringgit claims.
Standard CGL Exclusions
CGL doesn't cover everything. Each exclusion exists because another policy handles that risk. Understanding the exclusions helps you identify gaps in your programme.
| Exclusion | Why It's Excluded | What Covers This Instead |
|---|---|---|
| Employee injuries | Workers are covered under dedicated employee protection schemes | WC insurance / SOCSO / Employers' Liability |
| Professional negligence (design errors) | Requires claims-made policy with professional assessment | SPPI / Professional Indemnity |
| Damage to your own property | CGL covers third-party property only | IAR / Fire insurance |
| Damage to the contract works | Covered under project-specific construction policy | CAR / EAR Section I |
| Property in your care, custody, or control | You've assumed responsibility for this property. Standard CGL doesn't cover it. | Bailee's liability or contractual liability extension |
| Motor vehicle liability | Covered under motor insurance regulations | Motor policy (third-party section) |
| Gradual pollution / contamination | Not sudden and accidental; requires dedicated environmental policy | Environmental liability insurance (limited market in Malaysia) |
| Intentional acts | Insurance covers accidents, not deliberate harm | Not insurable |
| Contractual liability (assumed) | Standard CGL only covers liability you'd have even without the contract | Contractual liability extension (request from broker) |
The care, custody, and control exclusion is the one that catches industrial operators most often. If you're a logistics company holding client goods in your warehouse, standard CGL won't cover damage to those goods. You need a specific extension or bailee's liability policy. If you're a contractor working on existing property (renovations, maintenance), the property you're working on may fall under this exclusion.
Common CGL Extensions for Industrial Operations
| Extension | What It Adds | Who Needs It |
|---|---|---|
| Products and completed operations | Covers injury/damage from products sold or work completed and handed over | All manufacturers. Contractors doing handover-based work. |
| Contractual liability | Covers liability you've assumed under contract (indemnity clauses) | Contractors with back-to-back indemnity obligations to main contractors |
| Cross liability | Treats each insured party as if they had separate policies (for JV partners) | Joint ventures, consortium projects |
| Sudden and accidental pollution | Covers third-party claims from sudden chemical/oil spills (not gradual) | Chemical plants, factories handling hazardous materials, fuel storage |
| Loading and unloading | Covers liability during loading/unloading operations at client premises | Logistics operations, delivery crews, crane operators |
| Principal's indemnity | Extends CGL to cover your client/principal for vicarious liability from your work | Subcontractors where main contractor requires indemnification |
Industrial CGL Claim Scenarios
These scenarios show how CGL claims arise in real industrial and construction operations.
Scenario 1: Construction Site Debris Injury
A construction contractor is demolishing an old factory wall. Despite hoarding barriers, a piece of debris flies over the barrier and strikes a passing motorcyclist. The motorcyclist suffers a fractured arm and files a claim for medical expenses, lost income, and pain and suffering.
| Claim Component | Amount |
|---|---|
| Medical expenses (surgery, hospitalisation, rehabilitation) | RM45,000 |
| Lost income (3 months unable to work) | RM12,000 |
| Pain and suffering damages | RM30,000 |
| Motorcycle damage | RM8,000 |
| Legal costs (defence) | RM25,000 |
| Total CGL claim | RM120,000 |
Note: This happened away from the project perimeter, so CAR Section II would not apply. Only the contractor's CGL policy covers this scenario.
Scenario 2: Chemical Spill Affecting Neighbouring Factory
A chemical plant in Pasir Gudang experiences a sudden pipe rupture. Process chemicals leak through the drain system and contaminate the neighbouring factory's water supply and finished goods. The neighbour files a claim for damaged stock and decontamination costs.
| Claim Component | Amount |
|---|---|
| Contaminated stock replacement | RM350,000 |
| Decontamination and cleanup | RM180,000 |
| Business interruption (neighbour's lost production) | RM220,000 |
| Legal and investigation costs | RM50,000 |
| Total CGL claim | RM800,000 |
This is covered under CGL with the sudden and accidental pollution extension. The key word is "sudden": the pipe rupture was unexpected. If the contamination had been gradual (ongoing minor leaks over months), the pollution exclusion would apply.
Scenario 3: Manufactured Component Failure
A metal fabrication company in Klang supplies structural steel brackets to a construction project. Six months after installation, one batch of brackets shows weld defects under load testing. The main contractor must shut down an entire floor to remove and replace the defective brackets.
| Claim Component | Amount |
|---|---|
| Removal of defective brackets | RM85,000 |
| Replacement brackets (supply and installation) | RM130,000 |
| Project delay costs (liquidated damages to main contractor) | RM200,000 |
| Total CGL products liability claim | RM415,000 |
This is a products liability claim: the damage occurred after the product left the manufacturer's premises. Without the products and completed operations extension on their CGL, the fabricator would bear the full cost.
Scenario 4: Forklift Damage at Client's Warehouse
A logistics company's forklift operator accidentally reverses into a client's automated storage rack system while unloading at the client's warehouse. The impact damages the rack and destroys RM120,000 worth of stored inventory.
| Claim Component | Amount |
|---|---|
| Rack system repair | RM75,000 |
| Destroyed inventory | RM120,000 |
| Total CGL claim | RM195,000 |
CGL in Your P&E Insurance Programme
CGL is the liability component that completes your property and engineering programme. Your property policies (IAR, Fire) protect your own assets. Your engineering policies (MB, BPV, EEI) protect your equipment. CGL protects you when your operations harm others.
| For Contractors | For Manufacturers |
|---|---|
| CAR/EAR (project works) + CGL (operations liability) + WC (worker protection) + SPPI (design liability) | IAR/Fire (property) + MB/MLOP (equipment) + CGL (operations + products liability) + WC (worker protection) |
Many contractors treat CGL as an afterthought or only buy it when a contract demands it. The smarter approach is maintaining an annual CGL policy that covers all your operations year-round. Annual policies are cheaper per day of coverage than project-specific policies, and they ensure you're never caught without liability protection between projects.
Talk to Foundation about structuring CGL within your P&E programme
FAQ
Is CGL insurance mandatory in Malaysia?
No, CGL is not legally required. But it's contractually required for most construction projects, government tenders, PETRONAS vendor registration, and many manufacturing supply chain agreements. If you bid on commercial or government projects, you'll need CGL as a condition of the contract.
What's the difference between CGL and CAR Section II?
CAR Section II covers third-party liability only at the specific insured project site and only during the project period. CGL covers your operations everywhere, across all projects and locations, for the full policy year. If you cause damage away from a project site (at your yard, during transit, at a client's premises), only CGL responds.
Does CGL cover my employees if they get injured?
No. Employee injuries are explicitly excluded from CGL. Your workers are covered under workmen compensation insurance (for foreign workers and SOCSO-exempt employees) and SOCSO (for Malaysian employees). Employers' liability insurance covers common law claims from employees beyond WC/SOCSO.
What's the typical CGL premium for a contractor?
Premiums typically range from 0.05% to 0.40% of annual turnover, depending on risk classification, claims history, and coverage limits. A medium-sized contractor with RM20M turnover and RM3M CGL limit might pay RM8,000-15,000 annually. Chemical and O&G contractors pay higher rates due to elevated risk profiles.
Can I add products liability to my CGL?
Yes. Products and completed operations coverage is a standard extension to CGL policies. For manufacturers, it's not optional: if your products enter the supply chain, you need this extension. It covers injury or damage caused by your products after they leave your factory gate.
What is the care, custody, and control exclusion?
This exclusion means CGL does not cover damage to property that is in your possession, under your control, or that you've been entrusted with. For example, if you're a contractor working on a client's building and you damage the building, the CCC exclusion may apply. This is one of the most commonly triggered exclusions in industrial CGL claims. Ask your broker about contractual liability extensions that may address this gap.
Do I need separate CGL for each project?
No. An annual CGL policy covers all your operations across all projects and locations for the policy year. This is more cost-effective and administratively simpler than buying project-specific CGL. The only exception is when a specific project requires CGL limits higher than your annual policy, in which case you may need a project-specific excess layer.
What happens if my CGL limit is too low?
If a claim exceeds your policy limit, you're personally liable for the excess. For example, if you have RM2M CGL and face a RM3M claim, your insurer pays RM2M and you pay RM1M from your own resources. Malaysian courts have awarded damages exceeding RM5M in serious industrial injury cases. Setting adequate limits is one of the most important decisions in your insurance programme.
Does CGL cover my subcontractors?
Your CGL does not automatically cover your subcontractors. Each subcontractor should carry their own CGL. You can, however, be named as an additional insured on their CGL policy (and vice versa). Main contractor agreements typically require subcontractors to maintain their own CGL with minimum limits.
How does CGL interact with OSHA 1994 penalties?
CGL does not cover OSHA 1994 fines and penalties. Regulatory penalties (up to RM500,000 under the 2022 Amendment) are the employer's direct liability. CGL covers civil claims from injured third parties, not government enforcement actions. Strong safety compliance reduces both your OSHA exposure and your CGL premium.
Foundation Conclusion
Your CAR policy protects the works. Your IAR protects your factory. Your WC protects your workers. But when your operations cause injury or damage to someone else's property or person, CGL is what stands between you and a direct financial hit. For contractors and manufacturers, it's the liability layer that completes the P&E programme.
CGL is affordable relative to the exposure it covers. The cost of not having it is one bad incident away from becoming clear.
Get a CGL quotation structured for your industrial operations
Disclaimer: This article provides general guidance on insurance coverage available in the Malaysian market. Policy terms, conditions, and availability vary by insurer. Always review your specific policy wording or consult a qualified insurance professional before making coverage decisions.
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