OH Consultant

You Have 40 Subcontractors. How Many Are Compliant Right Now?

A SafeWork inspector asks you for the induction record of a subcontractor's apprentice on your site. You do not have it. The subcontractor said they would handle it. They did not. The improvement notice has YOUR company name on it — not theirs. Principal contractor liability under s.16 of the WHS Act means their failure is your problem.

~$2,235,363
Category 2 penalty for body corporate
WHS Act 2011, CPI-indexed 2025-26
~$447,122
Officer personal penalty (Cat 2)
WHS Act 2011, CPI-indexed 2025-26
$20,000,000
Industrial manslaughter maximum
WHS Amendment (Industrial Manslaughter) Act 2024

The risks of managing subcontractor compliance manually

Subcontractor insurance expires without notification

A subcontractor's workers compensation insurance expired two weeks ago. Their worker is injured on your site. The workers compensation claim falls to your insurer because the subcontractor was uninsured at the time of the incident. You had no system to alert you when the policy lapsed. The cost of the claim, the premium increase, and the regulatory investigation could have been avoided with a single expiry alert.

WHS Act 2011 s.16, s.20; Workers Compensation Act 1987

SafeWork holds you responsible for subcontractor workers

WHS Act s.16 provides that your duty of care extends to every worker on your site, including subcontractor workers. Section 20 imposes a specific duty on the PCBU who manages or controls the workplace. When SafeWork investigates an incident involving a subcontractor's worker, the improvement notice or prosecution frequently names the principal contractor. Your defence depends on demonstrating you had systems to verify subcontractor compliance — not just intentions.

WHS Act 2011 s.16, s.20

Managing 40+ subcontractors in email threads and spreadsheets

Insurance certificates in email attachments. SWMS in shared folders. Training records in spreadsheets. Induction records on paper sign-in sheets. When you need to verify that Subcontractor #23 has current insurance, a reviewed SWMS, and inducted workers for tomorrow's task, you are searching through 4 different systems. The information exists — but you cannot access it fast enough when it matters.

WHS Regulation 2025 s.309 (WHS management plan must address subcontractor management)

What you get with Principal Contractor

Building
Traffic light dashboard — green/amber/red per subcontractor
Every subcontractor has a compliance profile showing insurance status, SWMS status, training records, and induction completions. Green means fully compliant. Amber means something expires within 30 days. Red means a gap exists. See the status of all 40 subcontractors on one screen.
Project meeting. Pull up the Subcontractor Register. 32 green, 5 amber, 3 red. The 3 reds: one has expired public liability, one has a SWMS pending review, one has a worker without site induction. Address all three before tomorrow.
Bell
Alerts to both you and the subcontractor
When a subcontractor's insurance, licence, or training record approaches expiry, both the principal contractor and the subcontractor receive alerts 30 days before. No more discovering expired documents when the worker arrives on site.
Alert: 'ABC Electrical public liability insurance expires in 28 days. Subcontractor notified.' ABC Electrical renews and uploads new certificate. Status returns to green. No site disruption.
ClipboardCheck
No induction = no site pass
Digital site induction completed on any device before site access is granted. System enforces the rule: no induction record = no site access. Every worker who enters the site has a documented, date-stamped induction record.
Subcontractor sends a new worker to your site. Worker completes digital induction on their phone in the car park. Induction recorded. Site access granted. If they skip it, the system flags them as non-inducted.
Award
Automated compliance scoring with minimum threshold
Define your minimum compliance threshold for site access. System scores each subcontractor against your criteria. Below threshold = no site access until gaps are closed. Transparent, consistent, and documented.
Your threshold: 80% compliance score. Subcontractor XYZ scores 72% — missing updated SWMS and one worker's first aid has expired. System blocks site access. XYZ uploads updated SWMS and renewed certificate. Score rises to 91%. Access granted.
FileCheck
Upload, review, comment, approve or reject
Subcontractors upload their SWMS. Your safety team reviews, adds comments, and approves or rejects with documented reasons. Workers sign the approved version on their devices. Complete audit trail from submission to sign-on.
Subcontractor uploads SWMS for working at height. Your safety manager reviews, notes that the rescue plan is missing. Rejects with comment. Subcontractor revises and resubmits. Approved. Workers sign before starting.
BarChart
Export per-project subcontractor compliance summary
Generate compliance reports showing subcontractor status across all active projects. Export for Tier 1 head contractor reporting, project meetings, or board-level WHS reports.
Monthly Tier 1 report due. Export compliance summary: 40 subcontractors, 92% average compliance score, 3 improvement actions in progress, zero expired insurance policies. Report generated in 2 minutes.

See EHS Atlas configured for principal contractors

One dashboard showing every subcontractor's compliance status across every project.