A new contract starts at short notice, officers go sick, a client adds night cover, or a site needs a full team by Monday. Subcontracting officers is a normal way for security companies to cope, but the legal responsibility does not move with the shift. This guide covers what the rules say, what to check, and what to ask a supply partner.
The licensing rules still apply to you
Under the Private Security Industry Act 2001, an individual doing licensable work as part of a contract for services needs the right SIA licence, and supplying an unlicensed operative for that work is a criminal offence.
The rules also reach the people who run these businesses. If you are a director, partner, manager or supervisor of a business that supplies security operatives under contract, you need a front line or non-front line SIA licence, depending on whether you personally carry out licensable activities. The requirement covers non-executive directors, shadow directors and directors of parent companies, so it can apply even if “director” is not in your job title.
You are still responsible when you subcontract
Your client contracts with you, so every officer on that contract reflects on you, whoever employs them. In practice that means checking each officer’s licence on the SIA Register of Licence Holders before they are deployed, recording the licence type and expiry date, and checking again when a contract is extended or changed. A licence check is not a one-off task at recruitment.
The SIA has prosecuted people who assumed a licence was valid and never checked the register. It is a simple step that takes minutes, and it is the one that matters most if something goes wrong.
Approved Contractor Scheme rules
The SIA’s Approved Contractor Scheme is voluntary. If your company is an approved contractor, the SIA states that approved contractors may only subcontract to other approved contractors unless it has given them special permission. Check the scheme rules and your own approval before you subcontract. Some clients also write approved-contractor requirements into their tenders or premises licence conditions, so read your contract before you commit.
What to ask a supply partner
- Will every officer hold the correct, current SIA licence for the post, and will you receive the details in advance so you can check the register yourself?
- Who employs or engages the officers, and how are right-to-work checks and vetting carried out?
- Who supervises the officers on site, and how can your control room reach them?
- How are absences and late cancellations covered?
- Can the partner work to your assignment instructions, uniform and reporting standards?
- What insurance is in place, and can you see the certificates?
- What are the rates, notice periods and minimum hours, in writing?
Put it in writing
A short written agreement avoids most disputes. It should set out the roles, locations, hours and rates, the licence and vetting evidence you will receive before each shift, notice and cancellation terms, how replacements work, insurance, who gives instructions on site, and how personal data about officers and clients is handled. Take legal advice on your own contract terms.
How GM Secure can help
GM Secure supplies SIA-licensed, DBS-checked officers to other security companies as well as working directly with clients, across London and the UK, including 24/7 cover. Tell us the site, the role, the hours and the notice you have, and we will say honestly whether we can cover it. If your contract or your own approval requires approved-contractor-only supply, please tell us at the outset so we can be clear about whether we are able to help. Read more about our security placement and manned guarding services.
Official sources
- Find out if you need an SIA licence (GOV.UK)
- Find out if SIA licensing requirements for directors affect you (GOV.UK)
- Choosing an SIA approved contractor (GOV.UK)
- Check security staff have a licence to work (GOV.UK)
This article is general information, not legal advice. Rules can change, so check GOV.UK and take advice on your own contracts and approvals.