Subcontractors · Mandatory · Pre-Construction

Subcontractor Approval Form

A formal approval record confirming that a subcontractor has passed pre-qualification checks and is authorised to work on the project.

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 basis	CDM 2015 Reg 8
Purpose	The Subcontractor Approval Form is the formal record of the PC's decision to approve a subcontractor following PQQ review. It records: what was checked; the outcome; any conditions on approval; and who authorised the approval.
Approval levels	For smaller projects: site manager approval may be sufficient. For larger subcontract values: commercial manager + H&S advisor review. For significant structural or specialist subcontracts: director approval.
Conditions	Approval may be conditional: approved subject to provision of specific insurance documents; approved subject to H&S policy update; approved for this project only. Conditions must be tracked to closure.
Register	All approved subcontractors should be added to a project subcontractor register — a live record of all firms approved for and active on the project.

1. The Approval Form — Formal Sign-Off on the Competence Decision

The subcontractor approval form converts the PQQ review into a documented decision. It records that the PC has reviewed the PQQ responses, is satisfied that the subcontractor meets the CDM 2015 Regulation 8 competence requirements, has verified insurance is adequate, and has authorised the appointment at the appropriate level within the organisation. Without this form, there is no audit trail from PQQ to appointment.

The approval form should also capture any conditions or limitations on the approval — for example, that the subcontractor is approved for this specific project but not pre-qualified for future projects; or that approval is conditional on provision of a current CHAS certificate before mobilisation. Conditions must be tracked and confirmed as met before the subcontractor begins work.

A project subcontractor register derived from approval forms provides at-a-glance compliance visibility for the PC

The approval form is the trigger for adding the subcontractor to the project subcontractor register. The register tracks: company name; scope of work; approval date and approver; PQQ reference; CIS verification status; insurance expiry dates; CDM appointments made.

2. Approval Form — Content

Section	Detail
Subcontractor	Company name, address, company number. Principal contact.
Scope of works	Brief description of the package being approved.
PQQ reference	PQQ document reference. Date completed.
H&S assessment	Accreditation scheme and expiry / in-house assessment outcome. H&S policy reviewed Y/N. RIDDOR record reviewed Y/N.
Insurance check	EL cover level and expiry. PL cover level and expiry. PI cover (if applicable). Certificates seen and filed Y/N.
CIS status	GPS / 20% / 30%. Verification number. Date verified.
Financial check	References reviewed Y/N. Credit check outcome (if conducted).
Conditions	Any conditions on approval. Due date for condition resolution.
Decision	Approved / Conditionally Approved / Not Approved. Reason if declined.
Authorised by	Name, role, signature, date.

Common Mistakes

Approving subcontractors verbally without completing the form

Verbal approval followed by a subcontractor mobilising on site with no paper trail is a CDM compliance failure. The approval form must be completed before the subcontractor begins work.

Approval given at too low a level for significant subcontract packages

A £500,000 structural steel package approved by a site manager without commercial and H&S review lacks the appropriate governance. Approval authority levels should be proportionate to contract value and risk.

Conditions on approval never tracked or cleared

Conditional approvals that are never followed up mean subcontractors begin work before conditions are satisfied. Each condition must have a named responsible person and a due date.

Not reviewing approval when scope changes significantly

If a subcontractor’s scope expands significantly mid-project — adding structural works to a finishing package, for example — the original approval may not cover the expanded scope. Significant scope changes should trigger a review of the approval and competence check.

No project subcontractor register derived from approval forms

Individual approval forms filed in different places with no consolidating register means there is no quick way to identify which subcontractors are on site, what their approval status is, or when their insurance expires.

3. Frequently Asked Questions

Can a subcontractor start work while their approval conditions are outstanding?▾

No. A conditional approval with outstanding conditions means the competence check is not yet complete. The subcontractor should not begin work until all conditions are satisfied and confirmed in the form.

How does the approval form relate to CDM appointments?▾

CDM 2015 requires certain appointments to be in writing. For subcontractors, CDM Reg 8 requires the PC to check competence. The approval form is the pre-contract competence check; the subcontract agreement and the Work Package Brief formalise the CDM responsibilities in the contract.

Should the subcontractor see their approval form?▾

Not necessarily. The approval form is an internal PC document. However, if the approval is conditional, the subcontractor must be informed of the conditions that need to be met before work begins.

What happens if a subcontractor has been used on multiple projects — is a new approval required?▾

A subcontractor used on previous projects should be re-assessed at least annually or for each new significant project. Insurance policies renew annually — expiry dates change. Accreditations may have lapsed. A lighter-touch re-assessment is proportionate for well-known subcontractors — but some form of documented re-check is required.

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