Quick answer: A subcontractor in Australia generally needs SWMS for all high risk construction work activities, a WHS policy, current public liability and workers compensation certificates of currency, worker licences and white cards, plant pre-start checklists and registration documents, Safety Data Sheets for any chemicals used, induction records for their workers, and compliance with the principal contractor's site safety requirements. The exact documents required depend on your trade, the nature of the work, and what the principal contractor specifies.
Last reviewed: 12 June 2026
Subcontractors working in the Australian construction industry carry their own WHS obligations — separate from, and in addition to, those of the principal contractor. Many subcontractors are surprised by how extensive those obligations are, particularly if they are a sole trader or small operator who assumes the principal contractor's paperwork covers everyone on site. It does not.
This guide sets out the key WHS documents a subcontractor typically needs to mobilise on a construction site in Australia, explains the purpose of each, and outlines what principal contractors commonly require before granting site access.
Note: WHS legislation in Australia is based on the model Work Health and Safety Act 2011 developed by Safe Work Australia, but each state and territory has its own laws and regulators. Always check the requirements in your jurisdiction.
At a glance
| Document category | Examples |
|---|---|
| Risk management | SWMS for all HRCW activities |
| Business WHS system | WHS policy, incident register, hazard register |
| Insurances | Public liability certificate of currency, workers compensation certificate of currency |
| Worker credentials | White cards, high risk work licences, trade certificates, permits |
| Plant and equipment | Pre-start checklists, plant registration, operator licences |
| Hazardous materials | Safety Data Sheets (SDS) for all chemicals used on site |
| Induction and training | Site induction records, toolbox talk records, training register |
Core WHS documents required
The following table summarises the documents most commonly required or expected for a subcontractor working in the construction industry.
| Document | Why it is needed |
|---|---|
| Safe Work Method Statements (SWMS) | Required for all high risk construction work activities performed; must exist before work commences |
| WHS Policy | Demonstrates your business's commitment to managing health and safety; frequently requested by principal contractors |
| Public Liability Certificate of Currency | Evidence of current public liability insurance; required by most principal contractors before site access |
| Workers Compensation Certificate of Currency | Evidence of current workers compensation cover; required where the subcontractor has employees |
| Worker Licences and Tickets | High risk work licences, trade licences, and other tickets relevant to the scope of work |
| White Cards | Evidence each worker has completed general construction induction training |
| Plant Pre-Start Checklists | Completed before each shift for powered plant and equipment; documents the plant is fit for use |
| Plant Registration Documents | Registrable plant must have current registration; relevant documents must be available on site |
| Safety Data Sheets (SDS) | Required for all hazardous chemicals used on site; must be accessible to workers |
| Site Induction Records | Confirms each worker has received and understood site-specific safety information |
| Training Register | Records of qualifications, licences, and training completed by workers |
| Incident Register | Records incidents, near misses, and injuries involving your workers |
| Toolbox Talk Records | Documents safety briefings conducted with your workers on site |
SWMS for high risk construction work
The most important document a subcontractor must have in place is a Safe Work Method Statement (SWMS) for every high risk construction work (HRCW) activity they perform. Under the model WHS Regulations, a SWMS must be prepared before HRCW commences — not on the day work starts, and not after the fact.
High risk construction work includes, but is not limited to:
- Work at heights greater than 2 metres
- Demolition of load-bearing structures
- Work in or near confined spaces
- Excavation deeper than 1.5 metres
- Work involving pressurised gas distribution mains or piping
- Work near energised electrical installations or services
- Work in areas with artificial extremes of temperature
- Work in or near water or other liquids where there is a risk of drowning
A SWMS must identify the HRCW activity being carried out, the hazards associated with it, and the specific risk controls that will be applied. It must be kept on site and made readily accessible to workers performing the activity. Workers should be briefed on the SWMS before commencing work and should have the opportunity to ask questions.
On most construction sites, the principal contractor will require subcontractors to submit SWMS as part of the pre-mobilisation process. The principal contractor may review and request amendments to SWMS before approving site access. Even where the principal contractor reviews your SWMS, the legal obligation to prepare a compliant SWMS rests with the subcontractor performing the work.
For more detail on SWMS obligations, see: Do Subcontractors Need Their Own SWMS?
WHS policy
A WHS policy is a written statement by the person conducting a business or undertaking (PCBU) — in this case, the subcontracting business — setting out its commitment to managing health and safety, the roles and responsibilities involved, and how WHS is managed in practice. A written WHS policy is broadly expected for any construction business, regardless of size, and is routinely requested by principal contractors as part of their subcontractor pre-qualification process.
A WHS policy does not need to be lengthy, but it should be current, signed by the business owner or principal, and reflect how WHS is actually managed in the business.
Insurance documents
Before mobilising to a construction site, a subcontractor will almost always need to provide current certificates of currency for:
- Public liability insurance: Most principal contractors require a minimum of $10 million to $20 million in public liability cover. The certificate must be current and in the name of the subcontracting business.
- Workers compensation insurance: Required for subcontractors who have employees. The certificate must be current and cover the relevant state or territory where work is being performed.
Sole traders or partners without employees may need to provide evidence of personal accident insurance or a statutory declaration confirming they have no employees, depending on the principal contractor's requirements. Always check what is required before mobilising.
Worker licences, tickets, and white cards
Every worker a subcontractor sends to a construction site must hold a current white card (general construction induction training card). This applies to all workers, including the business owner or sole trader.
Beyond white cards, many construction activities require a high risk work licence issued by the relevant state or territory regulator. High risk work licences are required for activities such as:
- Scaffolding (basic, intermediate, advanced)
- Rigging
- Dogging
- Crane and hoist operation (various classes)
- Forklift operation
- Pressure equipment operation
Where workers carry out licensed work, subcontractors should maintain copies of current licences in their training register and be prepared to produce them on request from the principal contractor or a WHS inspector.
Depending on the trade, additional certificates or tickets may also be required — for example, a gasfitter's licence, an electrical contractor licence, a plumber's licence, or an asbestos removal licence. The relevant licensing requirements vary by state and territory.
Plant pre-start checklists and registration
Subcontractors who bring plant and equipment to site — including excavators, elevated work platforms, compressors, concrete saws, and similar equipment — have obligations around pre-start inspection and, for registrable plant, registration.
Pre-start checklists should be completed before each shift for all powered plant and equipment. The checklist confirms the plant is in serviceable condition, any defects are identified, and the plant is safe to operate. Completed pre-start checklists form part of the site safety record.
Registrable plant (such as boilers, pressure vessels, lifts, cranes, and some other items prescribed under WHS regulations) must be registered with the relevant state or territory regulator. Registration documents should be available on site. Operators of registrable plant may also be required to hold a current high risk work licence.
Safety Data Sheets for hazardous chemicals
If your work involves the use of hazardous chemicals — including paints, adhesives, solvents, welding gases, epoxies, or any substance classified as hazardous — you are required to have a current Safety Data Sheet (SDS) for each product. The SDS must be:
- Obtained from the manufacturer or supplier
- Current (within the last 5 years is commonly expected)
- Accessible to workers at or near the location where the chemical is used
Subcontractors should not rely on the principal contractor to provide SDS for chemicals they bring to site. It is your obligation to manage the chemicals your business introduces. SDS should be reviewed before using a new product on site and should be incorporated into your SWMS where the chemical use is part of a HRCW activity.
Site induction records
Before any of your workers access a construction site, they must complete a site induction covering site-specific hazards, emergency procedures, first aid arrangements, site rules, and reporting requirements. The principal contractor typically runs this induction and provides written confirmation or a sign-off record.
As a subcontractor, you are responsible for ensuring all of your workers — including new starters, casuals, and further subcontractors you engage — complete the site induction before commencing work. Maintaining your own record of who from your business has been inducted on each site is good practice and supports your duty as a PCBU to manage risks.
What principal contractors typically require
Principal contractors in the construction industry have broad obligations under the WHS Act and Regulations, including obligations to manage the WHS of everyone on their site. To discharge those obligations, most principal contractors require subcontractors to complete a pre-qualification or pre-mobilisation process before site access is granted. This process commonly includes:
- Submission and review of SWMS for all HRCW activities to be performed
- Provision of current insurance certificates (public liability and workers compensation)
- Evidence of relevant licences and white cards for all workers
- Review of the principal contractor's site WHS management plan and site rules
- Completion of site induction by all workers
- Provision of plant registration and inspection records for any plant being brought to site
- Confirmation of SDS availability for any hazardous chemicals being brought to site
The scope of pre-qualification requirements varies between principal contractors and projects. On large commercial or civil construction sites, the process may be extensive. On smaller residential sites, it may be more straightforward. In all cases, it is the subcontractor's responsibility to find out what is required and to have documentation in order before mobilising.
For a broader overview of what to prepare before starting on site, see: WHS Documents Before Starting on Site
Example scenario
Consider an electrical subcontractor operating in New South Wales with two employees. The business has been engaged by a principal contractor on a commercial fitout project. Before mobilising to site, the business would typically need to have ready:
- SWMS prepared for work near energised electrical installations and any work at heights involved in the scope
- WHS policy current and signed
- Public liability certificate of currency for $20 million, in the business name
- Workers compensation certificate of currency current for NSW
- White cards for all three workers (including the owner)
- Electrical contractor licence (NSW Fair Trading) and any relevant electrical worker licences
- Pre-start checklist template for powered tools and any elevated work platforms to be used on site
- SDS for any chemicals to be used (e.g. cable lubricant, cleaning agents)
- Site induction records confirming all workers have completed the principal contractor's site induction
This business would also need to review the principal contractor's site WHS management plan and site rules, submit SWMS for review, and register workers in the site induction system before any work commences.
Frequently asked questions
Do subcontractors need their own SWMS or can they use the principal contractor's?
Subcontractors must prepare their own SWMS for each high risk construction work activity they perform. The principal contractor's WHS management plan does not substitute for a subcontractor's SWMS. In many cases the principal contractor will review and accept the subcontractor's SWMS as part of the pre-mobilisation process, but the obligation to prepare the SWMS rests with the subcontractor performing the work.
What insurance documents does a subcontractor typically need to provide?
Most principal contractors require subcontractors to provide a current certificate of currency for public liability insurance (commonly $20 million cover) and workers compensation insurance before allowing access to site. Sole traders or partnerships without employees may need a specific form of personal accident insurance in lieu of workers compensation — check the requirements with the principal contractor before mobilising.
Does a subcontractor who is a sole trader still need WHS documents?
Yes. A sole trader is a person conducting a business or undertaking (PCBU) under the WHS Act and has the same duty to manage risks as any other PCBU. Even without employees, a sole trader carrying out high risk construction work must prepare SWMS before starting work, hold a current white card, hold any relevant high risk work licences, and comply with the principal contractor's site safety requirements. A written WHS policy is also broadly expected.
How long should a subcontractor keep WHS records?
General WHS records such as SWMS, induction records, and toolbox talk records should be kept for at least the duration of the project, and typically for several years afterwards in case of a legal or regulatory matter. Incident records and workers compensation records may need to be kept for longer periods under your state or territory's laws. Check with the relevant WHS regulator in your jurisdiction for retention requirements.
Get your WHS documents in order
Blue Safe Online provides ready-to-use WHS document systems for Australian construction businesses and subcontractors. Whether you are setting up a WHS system from scratch, preparing to mobilise on a new project, or updating outdated documents, the Blue Safe Online platform gives you access to professionally prepared SWMS, WHS policies, registers, SDS registers, pre-start checklists, induction records, and more — tailored to the construction industry.
Browse subcontractor WHS documents on Blue Safe Online
This guide provides general information only and does not replace legal advice or consultation with the relevant WHS regulator. WHS document requirements may vary by state or territory, project type, contract conditions, and the nature of your role on site.