Have You Got Sight of Your Subcontractors?

Ari Fatah, Technical Standards Manager at Veriforce CHAS

Subcontractors are fundamental to the roofing industry, enabling businesses to respond to changing demand, specialist requirements and seasonal workloads. But in a sector characterised by extensive subcontracting and layered supply chains, visibility can quickly diminish beyond the first tier. The company approved by a hiring business may not always be the company, or individual, that ultimately arrives on site.

Since 1 October 2026, the Right to Work regime has expanded beyond traditional employment relationships to cover organisations engaging subcontractors and certain other working arrangements.

Alongside the competence and accountability requirements associated with the Building Safety Act 2022, this reinforces the importance of understanding who is carrying out work, how they have been engaged and whether the appropriate checks and controls are in place.

The Hidden Subcontractor

Contractors will typically provide health and safety documentation, qualifications, certificates and other relevant information during pre-qualification and onboarding. These checks can support compliance with wider obligations, including those arising under the Building Safety Act 2022, the Construction (Design and Management) Regulations 2015 and the Health and Safety at Work Act 1974.

This supports initial pre-qualification and provides an important compliance baseline, but it does not necessarily show what is happening once work begins.

Work may be subcontracted through additional layers before reaching the company or individual who ultimately carries it out. As the chain grows, visibility can reduce and important questions arise. Who is actually on site? Who engaged them? Have they received the appropriate site induction? Is there evidence that they are competent for the work they have been asked to undertake? And, where applicable, have the required Right to Work checks been completed?

The distinction is important. Organisational pre-qualification can provide assurance that a contractor has appropriate systems, policies and evidence in place, but this needs to be complemented by effective on-site controls, including appropriate induction, supervision and checks relating to the specific work being undertaken.

Reputational, Financial and Safety Risks

Limited visibility can create serious health and safety risks, particularly in roofing, where working at height is routine and effective planning, competence and site controls are essential to worker safety.

The latest Health and Safety Executive (HSE) figures show that 124 workers were killed in work-related incidents in 2024/25, with construction accounting for the highest number of fatalities (35), and falls from height continue to be the leading cause of death. With working at height routine for roofing contractors, these figures reinforce the importance of knowing not only which organisations have been approved to work, but who is actually carrying out that work and whether the necessary controls are in place.

The potential consequences also extend beyond safety.

The expansion of the Right to Work regime means that organisations should understand how individuals within their supply chains are being engaged and where responsibility for the relevant checks sits. In certain circumstances, liability can extend beyond the direct engager and further up a contractual chain. This makes visibility and clearly defined responsibilities increasingly important.

Civil penalties can reach £45,000 per illegal worker for a first breach, rising to £60,000 for further breaches. Where supply chain visibility is limited, these penalties can have a significant impact on business and often come as a surprise for those higher up the supply chain, who have limited awareness of subcontractors beyond the first tier.

Compounding the financial penalty is the reputational damage of non-compliance, with its ability to influence the outcomes of future contracts and tenders, as well as recruitment and talent attraction. Beyond any direct penalties or disruption caused by compliance failures, poor supply chain management can affect customer confidence and potentially influence future contracts and tender opportunities.

Improving Visibility and Closing the Compliance Gap

For many businesses, the fundamental challenge is that it’s difficult to manage compliance for a supply chain you cannot see. This is why it’s important to move beyond a focus on initial onboarding towards more holistic workforce visibility.

The answer is not simply to add more checks at the point of onboarding. Businesses should consider how pre-qualification connects with the controls used throughout the working relationship and on site. Stronger processes across subcontracting tiers, supported by effective information sharing and site controls, can give organisations a clearer understanding of who is undertaking work on their behalf. They can also help businesses establish what evidence has been checked, whether it remains current and where gaps may need to be addressed. This creates a more reliable audit trail and supports more informed decisions while helping to ensure that the people arriving on site are expected to be there and appropriately assessed for the work being undertaken.

Building Confidence in the Supply Chain

Subcontracting will remain an essential feature of roofing, but visibility should not stop with the contractor named in the original appointment. As regulatory expectations around competence, accountability and workforce checks continue to evolve, businesses need proportionate processes that connect pre-qualification with current evidence, clear contractual responsibilities and effective controls on site.

By combining stronger supply chain visibility with effective on-site management, businesses are better placed to identify gaps earlier, demonstrate appropriate oversight and make more informed decisions about the organisations and individuals carrying out work on their behalf.

Find out how CHAS can help your business build a more visible and consistently assessed supply chain.

>> Read more about CHAS in the news