Quick answer: Before a subcontractor starts work, you should have a signed WHS agreement, verified current insurance (public liability and workers compensation), confirmed licences and tickets, a reviewed SWMS for any high-risk construction work, plant registration documents and pre-start records, SDS for any hazardous products they are bringing on site, a booked site induction, an entry in your contractor register, and a briefing on emergency procedures and site rules.
Last reviewed: June 2026 by the BlueSafe Technical Team. Reflects current Model WHS Act and Regulations.
Bringing a subcontractor on site creates shared WHS obligations. As the engaging party — whether you are the principal contractor, head contractor, or a PCBU managing your own premises — you cannot simply point to the subcontractor's ABN and consider your duty discharged.
The WHS Act requires that where more than one duty holder has obligations for the same matter, each must discharge their duty to the extent of their capability and influence. For subcontractor engagement, that means verifying credentials, reviewing work method statements, conducting inductions, and keeping records — before the first tool is lifted.
The checklist below works through every step in the order you should complete it. Work through each section before the subcontractor arrives on site.
For a detailed guide on managing the documents involved, see How to Manage Subcontractor WHS Documents. For background on the register you will need to maintain, see What Is a Contractor Register.
1. WHS Agreement
- A written WHS agreement (or subcontractor WHS induction form) has been provided to the subcontractor.
- The agreement sets out the site WHS rules, the subcontractor's obligations under the WHS Act, and the consequences of non-compliance.
- The subcontractor has signed and dated the agreement.
- A copy has been retained on file and the original returned to the subcontractor.
- The agreement references your WHS Management System, site safety plan, or equivalent governing document.
2. Insurance Verification
Public Liability Insurance
- A current certificate of currency for public liability insurance has been collected.
- The policy name matches the trading entity that will perform the work.
- The coverage level is adequate for the scope and value of the work being performed.
- The policy expiry date has been noted and diarised for follow-up if work extends beyond that date.
Workers Compensation Insurance
- A current certificate of currency for workers compensation insurance has been collected.
- The policy covers the state or territory in which the work will be performed.
- The policy covers all workers the subcontractor intends to bring on site (including any labour hire).
- If the subcontractor is a sole trader with no employees, the status has been documented and the implications understood (sole traders may not be covered under standard workers compensation in some states — check your state regulator's guidance).
3. Licences and Tickets
- A list of the licences and tickets required for the subcontractor's scope of work has been identified.
- The following have been verified as current and photographed or copied for the file:
- High Risk Work Licence (HRWL) — for any relevant class (e.g. scaffolding, rigging, dogging, crane operation, EWP).
- Construction Induction (White Card or equivalent) for all workers entering a construction site.
- Electrical licence (if electrical work is within scope).
- Plumbing or gasfitting licence (if plumbing or gas work is within scope).
- Any other trade licence relevant to the scope (e.g. asbestos removal licence if applicable).
- Expiry dates for all licences have been recorded in the contractor register.
- Licences have been cross-checked against the relevant state licensing register where possible.
4. SWMS for High-Risk Construction Work (HRCW)
- The subcontractor's scope of work has been reviewed to identify any HRCW tasks.
- For each identified HRCW task, a SWMS has been requested from the subcontractor prior to work commencing.
- Each SWMS received has been reviewed for the following:
- The HRCW type is correctly identified and matches the scope of work.
- Each work step is broken down logically.
- Hazards are identified for each step.
- Controls are specified using the hierarchy of controls (elimination through to PPE).
- The SWMS references the specific site or conditions where applicable.
- Any deficiencies in the SWMS have been raised with the subcontractor and corrected before approval.
- The approved SWMS is available on site during the work.
- Workers performing the HRCW task have signed the SWMS to confirm they have read and understood it.
- A process is in place to review and update the SWMS if site conditions or the scope of work changes.
For guidance on what a compliant SWMS should contain, see How to Manage Subcontractor WHS Documents.
5. Plant and Equipment
Registered Plant
- The subcontractor has been asked to identify any registered plant they intend to bring on site (e.g. pressure vessels, forklifts, cranes, elevating work platforms, scaffolding).
- Design registration and item registration documentation has been sighted and copies kept on file.
- Current inspection or certification records have been sighted for all registered plant.
Pre-Start Checks
- A pre-start inspection process is in place for all relevant plant the subcontractor will operate on site.
- The subcontractor has confirmed they have a documented pre-start checklist for their plant.
- Pre-start records will be retained on site for the duration of the work.
- Any plant defects identified must be reported immediately and the plant tagged out of service until repaired.
6. Safety Data Sheets (SDS)
- The subcontractor has been asked to identify all hazardous chemicals and products they intend to bring on site.
- A current SDS (within 5 years of issue) has been received for each product.
- SDS are accessible in the work area where the chemicals will be used (physical copy on site or accessible via QR code or shared drive).
- The site's hazardous chemicals register has been updated to include any products the subcontractor is bringing on site.
- Workers who will use or be exposed to the chemicals have been informed of the relevant SDS controls and PPE requirements.
7. Site Induction
- A site induction has been booked or scheduled for the subcontractor and all of their workers before they commence work.
- The induction covers the following as a minimum:
- Emergency procedures, evacuation routes, and assembly points.
- Site-specific hazards and controls.
- PPE requirements for the site.
- Incident and near-miss reporting process.
- Prohibited areas or restricted access zones.
- Amenities, first aid facilities, and first aider locations.
- Drug and alcohol policy and any site-specific behavioural requirements.
- Environmental requirements (if applicable).
- Every subcontractor worker attending the induction has signed the site induction register.
- The induction date and attendees have been recorded in the contractor register.
8. Contractor Register
- The subcontractor has been added to the contractor register before work commences.
- The register entry includes: business name and ABN, contact details, scope of work, engagement dates, insurance details (type, insurer, policy number, expiry), licence numbers and expiry dates, induction date, and SWMS reference numbers.
- The contractor register is stored in a location accessible to site management.
- A process is in place to review and update the register entry if insurance or licences expire during the engagement.
For more information on what a contractor register should contain, see What Is a Contractor Register.
9. Emergency Procedures and Site Rules Briefing
- The subcontractor's supervisor or leading hand has been given a verbal briefing on emergency procedures (in addition to the written induction content).
- The subcontractor knows the location of the nearest first aid kit and the name of the site first aider.
- The subcontractor has been provided with or directed to the site emergency plan.
- Site rules — including PPE requirements, exclusion zones, traffic management, working hours, and any specific site behavioural rules — have been communicated in writing or as part of the induction.
- The subcontractor's supervisor has acknowledged receipt of the site rules and emergency procedures.
- After-hours emergency contact information for site management has been provided to the subcontractor.
Related guides
- How to Manage Subcontractor WHS Documents
- What Is a Contractor Register
- How to Write a Safe Work Method Statement (SWMS)
- What to Do When a SafeWork Inspector Visits Your Site
Frequently asked questions
Do I need to check a subcontractor's insurance before they start?
Yes. As the principal contractor or PCBU engaging the subcontractor, you have a duty to manage WHS risks arising from their work. Verifying that current public liability insurance and workers compensation insurance are in place is a fundamental step. An expired or inadequate policy leaves both parties exposed. Always collect a current certificate of currency — not just a receipt or renewal notice.
What is a SWMS and when does a subcontractor need to provide one?
A Safe Work Method Statement (SWMS) is a document that identifies the steps of a high-risk construction work (HRCW) task, the hazards associated with each step, and the controls that will be applied. Under the WHS Regulations, a SWMS must be prepared before any HRCW commences. If the subcontractor will perform any HRCW — such as work at heights above 2 metres, work involving excavation deeper than 1.5 metres, or demolition — they must provide a compliant SWMS for your review and approval before work begins.
Who is responsible for a subcontractor's WHS on site — them or us?
Both. Under the WHS Act, a PCBU has duties to workers and others whose work is influenced or directed by them — and this includes subcontractors. Where more than one duty holder has obligations for the same matter, each must discharge their duty to the extent they are capable. You cannot simply hand the risk to the subcontractor and walk away. You remain responsible for ensuring the site is safe and that the work is being performed in accordance with any SWMS, site safety rules, and your WHS Management System.
What goes in a contractor register?
A contractor register records all contractors and subcontractors engaged by the business. It typically includes the contractor's name and business details, the scope of work, dates of engagement, insurance details (and expiry), licence and certification details, induction date, and any SWMS references. Keeping a current register allows you to demonstrate that contractor WHS management is systematic rather than ad hoc. For more detail, see our guide to What Is a Contractor Register.
Get your contractor management documents sorted
A checklist gets you started — a WHS Management System keeps you compliant. Blue Safe Online provides ready-to-use, regulator-aligned WHS documents including contractor registers, SWMS templates, and site induction forms.
Ready to manage subcontractors with confidence? Explore Blue Safe Online.
This article is general information only and does not constitute legal advice. WHS laws vary between states and territories. Always confirm current requirements with your relevant state or territory WHS regulator or seek independent legal advice for your specific situation.