Checking officer licences: what a contractor is actually obliged to do

It is easy to assume that once an officer is licensed and on payroll, the licensing question is settled. In practice, the obligation to know an officer's licence is valid does not end at onboarding — it applies every time that officer is rostered onto licensable activity, which for most contractors is every working day.

What checking actually involves

The SIA maintains a public register that allows licence status to be checked, and using it is the practical way a contractor demonstrates due diligence, rather than relying on the physical card an officer carries, which shows what was true when it was issued rather than what is true today.

Where the obligation is most often treated too lightly

• –Checked once at onboarding, and never again for the life of the officer's employment
• –Checked by asking the officer to confirm their own status, rather than checking the register directly
• –Not checked at all for short-notice cover, where the pressure to fill a gap outweighs the pause to verify
• –Not checked for subcontracted officers, on the assumption that the subcontractor's own checks are sufficient — see subcontracted cover: whose compliance problem is it?

None of these are deliberate corner-cutting. They happen because checking feels like it was already done once, and repeating it does not feel proportionate to the risk — until the one time it was needed and was not there.

Evidencing the check, not just doing it

Doing the check and being able to show you did it are different things, and an assessment or investigation will generally ask for the second. A record of when a licence was last verified, and by what method, is what turns a good habit into something that can actually be produced on request.

Exactly what due diligence is expected of a contractor is set out in current SIA guidance and, often, in the client contract itself — both are worth checking directly rather than working from what has always been done.