Competence Is Now Something Contractors Have to Evidence, Not Assert

Published: 12 August 2026

For most of the last two decades, "competence" in UK construction functioned as a word you put in a pre-qualification response. Everybody wrote it. Nobody was often asked to prove it in detail.

That has changed, and the change is not confined to the buildings the Building Safety Act was written about. The standard of proof across the sector has moved, and contractors are increasingly asked for evidence on projects that sit well outside the higher-risk regime — because clients, principal contractors and insurers have all recalibrated what a reasonable answer looks like.

What actually changed

Three things happened roughly at once, and their combined effect is larger than any one of them.

The Building Safety Act introduced explicit competence duties for those carrying out design and building work, with supporting frameworks setting out what competence means for particular roles. The detail bites hardest on higher-risk buildings, but it established a vocabulary — skills, knowledge, experience and behaviours — that has propagated outwards through client requirements and insurance questions.

Card schemes tightened. The withdrawal of routes that allowed cards to be issued on the basis of experience alone removed a long-standing shortcut. The practical consequence is that a card now means something more consistent, and correspondingly that the absence of one is harder to explain away.

Client expectations moved faster than the law. This is the part contractors actually feel. Pre-qualification questionnaires now ask for individual-level evidence, mobilisation is gated on it, and the request often arrives with a few days' notice.

Skills, knowledge, experience — and behaviours

The fourth element is the one that trips people up, because it is the only one that is not evidenced by a certificate.

Most contractors can produce the first row within an hour and the last row not at all. Behaviours are observed constantly on site — a supervisor forms a clear view of who works safely — and that observation vanishes because there is nowhere to put it.

The card is the start of the evidence, not the end

This is worth stating plainly because a lot of site processes still treat the card check as the whole assessment.

A card evidences that a person satisfied a scheme's requirements when it was issued. It does not evidence that they are competent for the specific task they are about to perform, on this site, under this method statement, with this equipment. CDM 2015 places the duty on the appointing party to satisfy themselves that the person has the skills, knowledge, training and experience for the work. The card contributes to that judgement; it does not discharge it.

The gap shows up sharply around equipment. PUWER requires that people using work equipment have received adequate training in its use, the risks and the precautions. That is a per-person, per-equipment record with a date and an evaluator. It is also, in most contractors' systems, the record that takes longest to find.

Competence is per task, and tasks move

The structural difficulty in construction is that the unit of competence is the task, while the unit of workforce management is the person, and the unit of commercial obligation is the site. All three change independently.

• An operative competent for one activity is not automatically competent for the adjacent one.
• The same operative is ready for one site and blocked on another, because site requirements differ.
• Cards, tickets, refreshers, first aid and face fit testing each renew on their own interval, so there is no single date to watch.
• Crews get reassigned mid-week, which invalidates whatever was checked on Monday.

A spreadsheet per project models one of those three dimensions and breaks on the other two. It is why the honest answer to "is everyone on site competent for what they're doing" is often "probably, and I'd need a day to show you".

The part nobody owns: the supply chain

On a multi-contractor site the principal contractor is expected to be able to demonstrate that everyone working there is competent and inducted. Not everyone on their payroll — everyone on site.

The usual mechanism is an email to each subcontractor asking for records, followed by a folder of PDFs of varying quality, compiled into a spreadsheet by someone who has other work to do. By the time it is complete, operatives have rotated and it describes a workforce that has partly left.

Two things improve this materially without buying anything. First, agree the evidence format at contract stage rather than at mobilisation, so subcontractors know what fields they must supply. Second, hold the records against the project rather than against the subcontractor, so the question "who is on this site and are they ready" can be answered without reassembling anything.

Contractor checklist

• Define requirements per site, not one company-wide standard, because clients differ.
• Define requirements per task as well as per role, particularly for high-risk activities.
• Record equipment training with the evaluator, the date and the equipment class — PUWER expects it.
• Capture supervisor observations somewhere, so behaviours are evidenced rather than merely known.
• Calculate renewals from each person's own dates and surface them weeks ahead of the gate.
• Deliver site induction before mobilisation, with a recorded knowledge check per operative.
• Agree subcontractor evidence fields at contract stage, and hold them against the project.
• Retain records after project close — evidence requests often relate to work already finished.

The commercial argument

It is tempting to treat this as a compliance overhead. The more useful framing is that competence evidence has become a commercial capability. Contractors who can answer a client's evidence request the same day are easier to appoint than contractors who need a fortnight, and that difference is now visible during pre-qualification rather than only after something goes wrong.