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CDM 2015 Core · Mandatory · Pre-Construction

Competence Assessment — Contractor

This assessment verifies that a contractor has the skills, knowledge, training, experience, and organisational capability required under CDM 2015. It covers health and safety management systems, insurance, training records, and relevant accreditations. The principal contractor must not appoint a contractor who cannot demonstrate adequate competence.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. CDM 2015 Reg 8 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basisCDM 2015 Regulation 8(1) — competence required; Reg 8(2) — must not accept if not competent; Reg 8(3) — appointing party must take reasonable steps to check
Who must checkAny party making an appointment — client checks PD and PC; PC checks every contractor they appoint
WhenBefore the appointment is made — not after work has started
SSIP statusCurrent — widely accepted as baseline H&S pre-qualification across the industry
PAS 91 statusWithdrawn April 2023 — no longer an active BSI standard. Superseded by CAS.
CAS statusCurrent — mandatory for public sector works greater than £5.337m under PPN 03/24 (2024). Version 4 (July 2024) is current.
ProportionalityDepth of assessment must be proportionate to the risk and complexity of the work scope
Enforcing authorityHealth and Safety Executive (HSE)

1. What Is a Contractor Competence Assessment?

A Contractor Competence Assessment is the structured process by which a Principal Contractor — or a client on a single-contractor project — satisfies themselves, before making an appointment, that the contractor they are engaging has the skills, knowledge, experience and organisational capability to carry out the work safely.

It is the practical discharge of CDM 2015 Regulation 8(3), which places a positive duty on the appointing party to take reasonable steps to satisfy themselves that the organisation or individual they are appointing is competent. This is not a paper exercise — it is a legal obligation that requires genuine enquiry proportionate to the risk and complexity of the work being tendered.

“A person with a duty...to appoint a designer or contractor...must take reasonable steps to satisfy himself that the designer or contractor fulfils the conditions in paragraph (1).”— CDM 2015 Regulation 8(3)
“A designer or contractor must not accept an appointment...unless the designer or contractor has, or...will acquire, the skills, knowledge and experience and...the organisational capability...to fulfil that role...in a manner that secures the health and safety of any person affected by the project.”— CDM 2015 Regulation 8(2)

2. Two Levels of Competence

Competence under CDM 2015 operates at two distinct levels. Both must be addressed, but the assessment mechanisms differ. Understanding the distinction is critical because the most common industry pre-qualification schemes — such as SSIP — only cover one of the two.

Level 1: Organisational CompetenceLevel 2: Individual Worker Competence
Health and safety policy statementValid CSCS card (or equivalent scheme card)
Documented H&S management systemRelevant NVQ or SVQ for the trade
Risk assessment and method statement capabilityCompleted site-specific induction
Accident and incident reporting proceduresToolbox talk attendance records
Employers’ liability insurance (current)Trade-specific training certificates (e.g. IPAF, PASMA, confined spaces)
Public liability insurance (current)First aid certification where required
Evidence of workforce training and CPDProof of medical fitness where required (e.g. asbestos medical)
Previous project referencesSupervisor qualifications (SMSTS, SSSTS)
SSIP or equivalent accreditationAppointed person or lift supervisor certification where applicable
Environmental management arrangementsLanguage and literacy assessment where relevant

SSIP covers Level 1 (organisational) only — not Level 2 (individual workers)

SSIP accreditation confirms that a contractor's health and safety management system has been independently assessed. It does not verify the competence of individual operatives on site. The principal contractor must separately check that each worker holds valid qualifications and training for the tasks they will perform. Relying on SSIP alone is one of the most common assessment failures.

3. Assessment Schemes — SSIP, CAS and the Current Landscape

Several industry schemes exist to support competence assessment. Understanding which are current, which have been withdrawn, and what each one actually covers is essential to avoiding gaps in compliance.

SchemeFull nameScopeStatusNotes
SSIPSafety Schemes in ProcurementOrganisational H&S management system assessmentCurrentMutual recognition across all member schemes (e.g. CHAS, SafeContractor, Constructionline). Covers Level 1 only.
CASCommon Assessment StandardOrganisational pre-qualification covering H&S, financials, insurance, environmental, quality, equalityCurrentMandatory for public sector works >£5.337m under PPN 03/24 (2024). Version 4 (July 2024) is current. Supersedes PAS 91.
PAS 91Construction Pre-qualification Questionnaires (BSI)Standardised PQQ format for construction procurementWithdrawn April 2023No longer an active BSI standard. Superseded by CAS. Should not be referenced in new procurement.
CSCSConstruction Skills Certification SchemeIndividual worker competence verificationCurrentCovers Level 2 (individual). Card confirms identity, training, and qualification for a specific occupation. Not a substitute for organisational assessment.

What CAS covers — the 13 assessment areas

The Common Assessment Standard (Version 4, July 2024) assesses contractors across 13 areas: company information; financial information; insurance; health and safety policy; health and safety management; training, skills and qualifications; monitoring, audit and review; workforce involvement; accident reporting, recording and investigation; risk assessment and method statements; occupational health; equality and diversity; environmental management. CAS provides a broader assessment than SSIP, which focuses on H&S management alone.

SSIP mutual recognition — one certificate, accepted by all schemes

SSIP operates a mutual recognition framework. A contractor assessed by any SSIP member scheme (such as CHAS, SafeContractor, Constructionline Gold, or Acclaim) is recognised by all other member schemes without the need for re-assessment. This means a contractor only needs to hold one current SSIP-member certificate to satisfy the organisational H&S element of pre-qualification across the industry. The appointing party should verify that the certificate is current and issued by a recognised SSIP member — but does not need to require a specific scheme.

4. Proportionality — How Deep Should the Assessment Go?

CDM 2015 requires that the depth of competence assessment is proportionate to the risk and complexity of the work the contractor will carry out. A groundworks contractor excavating next to a live railway requires a far more rigorous assessment than a painter decorating an empty office. The table below provides practical guidance on how to calibrate the assessment.

Risk levelExample contractorsMinimum checksDepth
LowPainter, decorator, carpet fitterSSIP or equivalent; EL and PL insurance; CSCS cards for operativesBasic organisational check plus individual card verification
MediumElectrician, plumber, joiner, dry-linerSSIP; insurance; trade accreditations (e.g. NICEIC, Gas Safe); RAMS capability; CSCS/ECS cardsOrganisational check plus trade-specific accreditation and individual qualifications
HighDemolition, asbestos removal, structural steelwork, deep excavation, crane operationsSSIP; insurance; specialist licences (e.g. HSE asbestos licence); detailed RAMS review; supervisor qualifications; previous project references; site visitFull organisational assessment, specialist licence verification, individual competence check for every operative, and review of recent project track record
Public sector (>£5.337m)Any contractor on public works above thresholdCAS assessment (mandatory under PPN 03/24); all checks above as appropriate to riskCAS replaces bespoke PQQ. All 13 CAS areas assessed. Additional high-risk checks layered on top where applicable.

What proportionality means in practice:

Proportionality does not mean ‘less rigorous.’ It means appropriately rigorous. A low-risk contractor still requires an organisational check and individual card verification — you cannot skip assessment entirely because the work is straightforward. Equally, applying a 40-page PQQ to a carpet fitter is disproportionate and creates a compliance burden without improving safety. The test is: would a reasonable, competent principal contractor, knowing what they know about this work scope, consider this level of assessment sufficient? If the HSE investigated an incident, would the assessment record demonstrate that the appointing party took reasonable steps? If the answer to both questions is yes, the assessment is proportionate.

5. The Assessment Record — What to Document

The assessment must be recorded. An undocumented assessment is, for compliance purposes, an assessment that did not happen. The record should capture enough information to demonstrate that the appointing party took reasonable steps under Regulation 8(3). The following table sets out the fields a well-structured assessment record should include.

FieldWhat to record
Contractor nameRegistered company name and trading name (if different)
Company registration numberCompanies House registration number
Work scopeDescription of the work package being assessed for
Risk level assignedLow, medium, or high — with brief rationale for the classification
H&S policy reviewedYes/No — date of policy, signed by whom
SSIP/CAS accreditationScheme name, certificate number, expiry date, scope of accreditation
Insurance verifiedEL and PL policy numbers, insurer, expiry dates, indemnity limits
Trade accreditationsE.g. NICEIC, Gas Safe, FENSA, NASC — registration numbers and expiry dates
RAMS capabilityEvidence that the contractor can produce adequate risk assessments and method statements for the work scope
Training records reviewedCSCS/ECS card types and expiry dates for key operatives; supervisor qualifications (SMSTS/SSSTS)
Previous project referencesTwo or three references for similar work — including any directly requested by the assessor
Assessment outcomeApproved / Approved with conditions / Not approved
Conditions (if any)Specific conditions attached to the approval — e.g. additional training required before mobilisation
Assessed byName, role, and signature of the person who carried out the assessment, with date

Accept with conditions — a useful middle outcome

Not every assessment results in a clear pass or fail. ‘Approved with conditions’ is a practical and defensible outcome where a contractor meets most requirements but has specific gaps that can be closed before work begins. For example: a contractor may hold SSIP accreditation and appropriate insurance but not yet have SMSTS-qualified supervision for the specific site. Approving with a condition that an SMSTS-qualified supervisor is named and verified before mobilisation is proportionate and practical. The key is that conditions must be specific, documented, and tracked to closure — not left as vague commitments.

6. Common Mistakes

1

Treating SSIP as the complete assessment

SSIP confirms organisational H&S management only. It does not verify individual worker competence, trade-specific accreditations, insurance adequacy, or project-specific capability. A contractor with SSIP still needs a proportionate assessment of all other areas before appointment.

2

Assessing after appointment rather than before

CDM 2015 Regulation 8(3) requires the appointing party to take reasonable steps before making the appointment. Carrying out the assessment after the contract is signed — or worse, after the contractor has mobilised — is a breach of the regulations and removes the ability to reject an inadequate contractor without commercial consequences.

3

Not recording the assessment

If it is not written down, it did not happen. An undocumented assessment provides no evidence of compliance with Regulation 8(3). If the HSE investigates following an incident, the first thing they will ask for is the competence assessment record for the contractor involved.

4

Applying the same depth to every contractor regardless of risk

A 40-page PQQ for a painter is disproportionate. A two-line check for a demolition contractor is inadequate. The depth of assessment must be proportionate to the risk and complexity of the work scope. One-size-fits-all approaches fail the proportionality test in both directions.

5

Accepting expired certificates or insurance

An SSIP certificate, insurance policy, or CSCS card that has expired provides no assurance. Certificates must be verified as current at the point of assessment. Where a contractor’s accreditation is due to expire during the project, a condition should be attached requiring renewal evidence before the expiry date.

6

Failing to reassess for significantly different work scopes

A competence assessment is specific to the work scope being assessed. A contractor assessed as competent for internal painting is not automatically competent for external access scaffolding. If a contractor is appointed for a materially different work package, a new or supplementary assessment is required.

8. Frequently Asked Questions

Is a competence assessment legally required before appointing a contractor?

Yes. CDM 2015 Regulation 8(3) requires any party making an appointment to take reasonable steps to satisfy themselves that the contractor has the skills, knowledge, experience, and organisational capability to carry out the work safely. This must be done before the appointment is made.

Does SSIP accreditation mean a contractor is automatically competent?

No. SSIP confirms that the contractor’s organisational health and safety management system has been assessed against a recognised standard. It does not verify individual worker competence, trade-specific accreditations, insurance adequacy, or project-specific capability. SSIP is a valuable starting point — not the complete assessment.

What if a contractor refuses to provide the information requested?

A contractor who cannot or will not provide evidence of competence should not be appointed. CDM 2015 Regulation 8(2) also places a duty on the contractor not to accept an appointment if they are not competent. If they refuse to demonstrate competence, that itself is a significant concern.

How often should a competence assessment be renewed?

There is no prescribed renewal period in CDM 2015. In practice, assessments should be reviewed annually and whenever a contractor is appointed for a materially different work scope. Certificates, insurance, and accreditations should be checked for currency at each new appointment.

Is PAS 91 still a valid assessment framework?

No. PAS 91 was withdrawn by BSI in April 2023 and is no longer an active standard. It has been superseded by the Common Assessment Standard (CAS). Any pre-qualification process still referencing PAS 91 should be updated to reflect the current framework.

Does the assessment need to cover environmental and quality management as well as H&S?

CDM 2015 Regulation 8 focuses on health and safety competence. However, the Common Assessment Standard (CAS) — mandatory for public sector works above £5.337m — includes environmental management, equality and diversity, and quality management alongside H&S. For private sector projects, the scope of assessment is at the appointing party’s discretion, but best practice increasingly mirrors the CAS framework.

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This guide is for general informational purposes only and does not constitute legal advice. While every effort is made to ensure accuracy, regulations change and individual project circumstances vary. Construction Suite is a trading name of Xzist Digital Ltd, registered in England and Wales.

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