Managing Security Subcontractors: Who Is Responsible for Compliance?

First establish what is actually being supplied

The SIA distinguishes subcontracting a security service from obtaining labour that your business directs and manages. Its guidance says a subcontractor screens and vets its own operatives; where a company obtains labour, it must ensure screening and vetting have been done or perform its own checks. Staff management arrangements should be clear in either case.

That distinction affects how you organise oversight. Ask what the agreement requires in practice and who directs the work, rather than relying on the invoice description. The SIA warns that liability can arise where unlicensed staff or people without the right to work are deployed.

ACS rules need a separate check

SIA approved contractors generally may subcontract the approved security service only to other approved contractors, unless the SIA permits an exception. The SIA’s guidance explains the permission route and distinguishes labour supply. Check the current rules against the actual arrangement; do not assume that every temporary labour provider needs ACS approval.

Make the chain understandable

Create a deployment schedule that connects the end client, main contractor, any subcontractor or labour provider, and each operative. Include who checks evidence, who approves replacements and who manages the shift. This is our suggested operational record, not a new statutory form.

For example, if Company A wins a venue contract and Company B supplies a relief team, the record should show whether B is delivering a service or providing labour under A’s direction. It should also identify the person responsible for resolving a missing licence check.

Agree the handover points

• Describe the service or labour arrangement in the contract.
• Identify the person checking licences, screening evidence and any role-specific requirements.
• Agree client approval for subcontracting and changes where applicable.
• Name the on-shift supervisor and escalation contact.
• Set a process for late additions, substitutions and expired evidence.
• Retain the assignment record and the decision on each unresolved gap.

Review the arrangement when it changes

A supplier approved at mobilisation may use different people or another business later. Make those changes trigger a review rather than allowing the original approval to stand for every future team. Keep the reasons for decisions alongside the evidence available at the time.

Licence Ready connects company and operative records to deployment requirements. This helps a buyer or main contractor see the chain and the readiness gaps. Contracts, applicable licensing duties and operational management still need to be addressed by the organisations involved.