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.

Checked once is not checked

A licence verified at onboarding tells you the position on that day. Licences expire, and they can also cease to be valid before their expiry date. A contractor whose only check happened at recruitment is relying on a snapshot that ages from the moment it is taken.

What makes ongoing checking practical is deciding a frequency and a trigger set in advance — at intervals, when an officer moves to a new contract, and before any shift where the position has not been confirmed recently — rather than leaving it to judgement.

Common mistakes

• –Verifying at onboarding and treating it as settled
• –No defined frequency for re-checking
• –No check when an officer moves between contracts
• –Recording the outcome without recording when it was checked
• –Relying on the officer to report a change in status
• –No check for subcontracted or agency officers

What separates a check that actually protects you

Timing and coverage. A check performed at the point of rostering protects the shift about to happen; one performed periodically protects the position generally. Contractors who are comfortable here do both, and they apply the same standard to subcontracted and agency officers as to their own.

The record matters as much as the check. Knowing an officer is licensed is operationally useful; being able to show when you established that, and on what basis, is what answers the question afterwards.

One practical test: check one you verified a year ago

Take an officer verified at recruitment twelve months ago and re-check their status today, as though they were new.

Licences expire and can cease to be valid before their expiry date, and nobody volunteers that about themselves. A contractor whose only check happened at recruitment is relying on a snapshot that has been ageing ever since — and the same exercise applied to a subcontracted or agency officer usually produces a less comfortable answer still.

• –Define a re-check frequency rather than relying on recruitment
• –Re-check when an officer moves to a new contract
• –Record when a check was done and by whom, not just the outcome
• –Apply the same standard to agency and subcontracted officers
• –Do not rely on officers reporting a change in their own status