How to Manage Subcontractors on Site: A Compliance Checklist

Pre-qualification is done. Documents are collected. Inductions are complete. Your subcontractors are on site — now what?

This is where compliance management actually gets tested. The checks you ran before appointment don't stay valid forever. Insurance expires. New operatives arrive without being inducted. Method statements written for the first phase don't cover the work happening in week six. If you're only checking compliance at the start of a project, you're only managing the risk you can see on day one.

This checklist covers what to check daily, weekly, and monthly to maintain subcontractor compliance on a live UK construction site. For the full pre-qualification and appointment process, see our guide to managing subcontractors in construction.

Daily compliance checks

These are quick checks — 5 to 10 minutes during your morning walkdown:

• CSCS cards visible. Every operative on site should be wearing their CSCS card. If someone can't produce a valid card when asked, they shouldn't be working until it's verified. Under CDM 2015 Regulation 8, you must satisfy yourself that anyone carrying out work has the skills, knowledge, training, and experience to do so safely.
• PPE compliance. Are operatives wearing the correct PPE for their task? Hard hat, hi-vis, steel-toed boots are baseline — but specific trades may require additional protection (RPE for dusty work, harnesses at height, eye protection for grinding).
• Work matches the method statement. Is the work being done consistent with the RAMS the subcontractor submitted? If the scope has changed — different equipment, different location, additional hazards — the risk assessment must be updated before work continues.
• Site access control. No unauthorised personnel on site. This includes subcontractor operatives who haven't completed their site induction, visitors without sign-in, and anyone from firms that haven't been through pre-qualification.
• Welfare facilities. Toilets, washing facilities, drinking water, rest areas, drying rooms — all functioning and accessible. This is a principal contractor duty under CDM 2015.

Weekly compliance checks

Set aside 30 minutes once a week for these:

• New operatives check. Has any subcontractor brought new people on site this week? Every new operative needs a site-specific induction and CSCS card verification before starting work. Ask subcontractor supervisors directly — don't wait for them to tell you.
• Permit-to-work review. For high-risk activities (hot works, confined spaces, working at height, electrical work near live services), check that permits are current, conditions are being followed, and permits are being closed out after the work is complete.
• Near-miss and hazard review. Are near-misses being reported? If the site has had zero reported near-misses in a month, that usually means under-reporting, not a perfect safety record. Review any reports from the week and check that corrective actions were completed.
• Housekeeping and access routes. Cluttered access routes, materials stored in walkways, trailing cables — these are both CDM compliance issues and leading indicators of a site where safety standards are slipping.
• Subcontractor coordination. When multiple subcontractors are working in the same area, are their activities coordinated to prevent conflicts? Steelwork overhead while groundworkers are below. Electricians pulling cables through spaces where plasterers are working. Check the construction phase plan covers these interactions.

Monthly compliance checks

These take longer but catch the issues that daily and weekly checks miss:

• Insurance expiry review. Pull up every active subcontractor's EL and PL certificates. Are any expiring in the next 30 days? Chase renewals now, not after the cover lapses. A subcontractor whose employers' liability insurance has expired should not work on site — their employer faces a fine of up to £2,500 per day under the Employers' Liability (Compulsory Insurance) Act 1969, and allowing them to continue weakens your CDM compliance evidence. Our free insurance expiry calculator gives you a traffic-light view of which subcontractors are approaching or past their renewal dates.
• RAMS currency check. Has the work scope changed since the risk assessments were submitted? New phases, different equipment, changed site conditions — all require updated RAMS. Generic method statements that haven't been reviewed since the start of the project are a common CDM finding.
• CIS verification status. Subcontractor tax status can change. If you haven't re-verified with HMRC recently, you may be applying the wrong deduction rate. Check the CIS verification guidance for the current process.
• Training and competence evidence. For long-running projects, check that any time-limited training certifications (IPAF, PASMA, first aid, fire marshal) are still valid. These tend to have 1–3 year renewal cycles.
• Construction phase plan update. The plan should reflect what's actually happening on site. If new subcontractors have been appointed, phases have changed, or significant hazards have emerged, the plan needs updating. This is a principal contractor responsibility under CDM 2015 — see our principal contractor duties guide.

When you find a gap

Compliance gaps are inevitable. What matters is how quickly you identify and resolve them:

Immediate stop situations:

• Expired employers' liability insurance — stop work until a current certificate is provided (the employer's obligation under the EL Act, and evidence you need for CDM compliance)
• Operative on site without valid CSCS card — remove from site until verified (industry best practice and a common client requirement, supporting CDM Regulation 8 competence checks)
• Work being done without an adequate risk assessment — stop the task

Corrective action situations:

• RAMS not updated for current phase — subcontractor must submit revised RAMS before resuming that work scope
• Training certification expired — operative cannot carry out the activity requiring that certification until renewed
• Permit-to-work conditions not being followed — stop the permitted activity, review with the subcontractor

In every case, document what you found, when, and what action you took. A clear audit trail demonstrates you're meeting your duty to manage compliance "so far as is reasonably practicable" — the standard under UK health and safety law. When HSE inspects or a client audits, your records are the evidence.

Making it sustainable

Running these checks across 20 or 30 subcontractors with spreadsheets and memory is where most contractors struggle. The daily and weekly checks are manageable with discipline. The monthly checks — tracking insurance expiry dates, CSCS renewals, CIS re-verification, training certificates — are where manual processes break down.

Generate a complete list of what you need to track for your specific project with our free compliance checklist generator. For an overview of what dedicated subcontractor compliance software can automate, see our buyer's guide.

Sources

• The Construction (Design and Management) Regulations 2015 (SI 2015/51)
• HSE — Contractor roles and responsibilities under CDM 2015
• Employers' Liability (Compulsory Insurance) Act 1969
• GOV.UK — Construction Industry Scheme

This guide is for informational purposes and does not constitute legal advice. For project-specific compliance questions, consult a qualified health and safety professional.

Last reviewed: 11 March 2026