Subcontractors · Mandatory · Pre-Construction
Worker Competency and Qualifications Record
A record of individual worker qualifications, training certificates, and competency assessments.
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 + MHSWR 1999 Reg 13 |
| CDM duty | Regulation 8 requires competence verification at individual worker level |
| What to verify | Trade qualification, CSCS card, plant operator certificates (CPCS, IPAF), asbestos awareness training, task-specific certifications |
| Subcontractor duty | Each subcontractor verifies their own workers; PC should require competency records before site access |
| Difference from Training Matrix | Training Matrix (H19) is site-wide grid; Worker Competency Record is individual worker document |
1. Worker Competency — Verified Before Site Access
CDM 2015 Reg 8 requires that no contractor may arrange for a worker to carry out construction work unless satisfied the worker has the skills, knowledge, experience, and training necessary. The Worker Competency Record provides the individual-level document confirming what was checked, when, and by whom.
This is distinct from the Training Matrix, which provides a site-wide overview of competence across all workers. The Worker Competency Record is a per-worker document that accompanies each individual and records the specific qualifications, cards, and certifications that have been verified. It is the evidence that Reg 8 has been discharged at the individual level.
Competency verification must happen before site access — not during induction, not after the first week. If a worker arrives on site and their competency has not been checked, they should not pass through the gate. The record must be completed and signed off before the worker begins any construction activity.
Subcontractor responsibility
The subcontractor is responsible for their workers' competence — require them to provide records for each worker before mobilisation.
2. Worker Competency Record — Content
| Field | Detail |
|---|---|
| Worker details | Full name, employer, trade/role on site |
| CSCS card | Card type (blue/gold/black/green/red), card number, expiry date, confirmation that card type matches the trade being performed |
| Trade qualification | Qualification title, awarding body, certificate number, date of award |
| Plant qualifications | CPCS categories held (e.g. A59, A17), IPAF PAL categories (3a, 3b, 1b), card numbers, expiry dates |
| Asbestos training | Training category (A, B, or C), date completed, refresher due date |
| First aid | FAW or EFAW, certificate number, expiry date |
| WAH training | Working at height training, date completed, provider |
| Other site-specific requirements | Any additional certifications required by the project (e.g. confined spaces, abrasive wheels, PASMA) |
| Subcontractor declaration | Signed declaration by subcontractor confirming records are accurate and current |
| PC sign-off | Name, signature, and date of PC representative who verified the record |
3. Common Mistakes
Not requiring records before site access
The Worker Competency Record must be completed and verified before the worker enters the site. Allowing workers on site with the intention of checking competence later defeats the purpose of the record and is a breach of CDM 2015 Reg 8. If competence is not verified before access, an unqualified worker may already be performing high-risk tasks.
Checking CSCS cards only at induction and not tracking expiry
CSCS cards have fixed expiry dates, typically five years. A card verified at induction in month one may expire in month six of a twelve-month project. The record must include expiry dates, and expiries must be tracked throughout the project. An expired card means the worker is no longer demonstrably competent.
Not requiring asbestos awareness training records for pre-2000 building work
Any refurbishment or demolition work on buildings constructed before 2000 carries a risk of asbestos-containing materials. Asbestos awareness training is mandatory for all workers who may disturb ACMs. Failing to require evidence of this training for pre-2000 projects is a significant compliance gap.
Accepting self-declarations without verification
A worker stating they hold a qualification is not evidence of competence. Cards, certificates, and training records must be physically checked or verified through the relevant scheme database. Self-declarations without supporting documentation are not compliant with Reg 8.
Treating competency records as a one-time pre-project exercise
Competence is not static. Workers acquire new qualifications, existing certifications expire, and project requirements change. The record must be reviewed and updated throughout the project duration, not filed at induction and forgotten.
4. Frequently Asked Questions
Does CDM require the same check for all trades?▾
No. The check must be proportionate to the role and risk. A labourer carrying materials requires different competency evidence than a crane operator or asbestos removal operative. The depth and scope of verification should reflect the hazards associated with the specific tasks the worker will perform.
What if a worker has skills but no formal qualification?▾
CDM 2015 focuses on skills, knowledge, experience, and training — not exclusively formal qualifications. A worker with extensive demonstrable experience but no NVQ may still be competent. However, the CSCS scheme generally requires formal qualifications for skilled cards. The record should document whatever evidence of competence exists and note any gaps.
Who is responsible for a subcontractor's worker?▾
The subcontractor has the primary duty to verify their own workers' competence. However, the PC has an overarching duty under CDM 2015 to satisfy themselves that all workers on site are competent. In practice, the PC should require subcontractors to provide completed competency records and verify them before granting site access.
What is the CITB HS&E test?▾
The CITB Health, Safety and Environment test was a requirement for CSCS card applications, demonstrating basic health and safety knowledge. Requirements change periodically. Check current requirements at cscs.uk.com for the latest information on test requirements and card application processes.
Generate your Worker Competency and Qualifications Record on Construction Suite
Construction Suite walks you through every required section with a guided Q&A — built to CDM 2015 Reg 8 — and generates a professionally formatted document in minutes.
Get started freeThis 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.