Compliance Beyond the Core: Managing Subcontractor Risk in Security, FM & Cleaning Operations
In today’s increasingly regulated environment, companies operating in Security, Facilities Management and Commercial Cleaning face more than just internal workforce compliance. They’re also accountable for the legal and operational status of every individual delivering service on their sites, including subcontracted staff.
With stricter enforcement of SIA licensing, tougher penalties for illegal working and more thorough client audits, the risks of non-compliance are increasing. Crucially, primary contractors remain liable, even when breaches originate from subcontractors.
What’s at Stake?
Failure to ensure the compliance of subcontracted workers can result in:
- Civil penalties of up to £45,000 per illegal worker (first offence) or £60,000 for repeat breaches under the Immigration, Asylum and Nationality Act 2006
- SIA enforcement action for unlicensed security operatives, which may include:
- Unlimited fines (serious cases tried in the Crown Court)
- Criminal prosecution under the Private Security Industry Act 2001
- Suspension or loss of Approved Contractor Scheme (ACS) status
- Legal exposure under immigration, employment, and modern slavery laws (e.g. Modern Slavery Act 2015)
- Contract termination, exclusion from future tenders, or procurement blacklisting
- Reputational damage with clients, regulators or in the press
Whether it’s a cleaner lacking proper right-to-work documentation or a guard with an expired SIA licence, the responsibility for compliance sits squarely with the principal contractor.
Why Oversight Is No Longer Optional
In the past, many providers trusted subcontractors to “self-manage” compliance. That’s no longer acceptable, particularly in public sector or critical infrastructure contracts.
Clients now expect full transparency and accountability across the entire workforce, regardless of employment model.
You must know:
- Who is working on your sites
- Whether they are licensed, vetted and eligible to work
- When their credentials or permissions expire
- How quickly you can prove compliance if audited or inspected
Failing to carry out proper checks could void your “statutory excuse” and expose your business to fines, prosecution, or contract loss.
The Role of Workforce Management Technology
Modern workforce management platforms have become essential to managing compliance at scale.
Originally built for staff scheduling, payroll, and time tracking, today’s systems can also:
- Track SIA licence statuses and expiry dates
- Monitor right-to-work documentation and issue alerts
- Maintain real-time dashboards of site-wide compliance
- Create secure, digital audit trails for client and regulatory reviews
- Onboard subcontractors into the same compliance ecosystem as internal teams
By operating through a shared system, subcontractors become subject to the same compliance checks, controls and alerts, closing critical gaps.
Real-World Benefits
Embedding subcontractor oversight into your existing workforce platform offers:
- Stronger compliance across all labour sources
- Automated alerts on expiring licences or missing documents
- Simplified, searchable audit trails for inspections or tenders
- Reduced admin from paper checks or fragmented systems
- Stronger client trust through proactive risk mitigation
- A consistent standard, even when subcontractors run their own teams
Final Thought
With civil penalties now reaching £60,000 per worker and enforcement on the rise, manual compliance management or blind reliance on subcontractors is a strategic risk.
Technology doesn’t replace responsibility. But it provides the visibility, auditability and control needed to manage it at scale.
If you’re delivering services across multiple sites, with rotating or mixed workforces, subcontractor risk creates both a legal issue and a vulnerability. Closing that gap isn’t a luxury. It’s essential.