The Building Safety Act 2022 requires every main contractor to demonstrate that every person working on their site is competent for their role. A CSCS card is the industry-standard evidence of occupational competence — but the card you see on a Monday morning is only as good as the CSCS register check you ran before work started.
Not legal or tax advice
This article provides general information only and is not legal or tax advice. Rules depend on the specific facts of your situation. Always confirm your specific obligations with a qualified solicitor or accountant before relying on this guidance.
What is a CSCS card and why does it matter?
CSCS (Construction Skills Certification Scheme) cards are issued by CITB and affiliated bodies. Each card records the holder's name, photograph, occupation, NVQ/SVQ qualification level, card type, and expiry date. They are the construction industry's primary evidence of occupational competence — linking a qualification to a role on site.
Under the Building Safety Act 2022, the Principal Contractor — you, as the main contractor — is responsible for demonstrating that every person working on site is competent for their specific role. CSCS cards are the standard the industry and the HSE use to assess this. The duty extends across all workers under the Building Regulations etc. (Amendment) (England) Regulations 2023, which brought the competence framework into force for a wider range of building work. HSE's published competence guidance makes clear that the obligation sits with the Principal Contractor and cannot be delegated simply by subcontracting the work.
A subcontractor telling you they have a card is not evidence. Seeing the card is not evidence. Only a check against the CSCS register — which confirms the card is current, registered, and the card type matches the role — constitutes valid evidence.
CSCS vs CITB
CSCS is the scheme that administers the card programme and operates the Smart Check online register (cscs.uk.com/checkcards), which is the authoritative source for verifying card status. CITB (Construction Industry Training Board) is a separate industry training board. Some cards — such as Gas Safe and JIB — are affiliated with CSCS but managed by their own schemes. The CSCS register covers all CSCS-affiliated cards.
CSCS card types explained
There are several distinct card types within the CSCS scheme. Each reflects a different level of qualification and a different scope of permitted work. Understanding the distinction matters because accepting the wrong card type for a given role does not satisfy the competence duty — and substituting one card for another is one of the most common compliance errors on UK construction sites.
Labourer (Green card). Held by workers who have passed the CSCS health, safety and environment test but hold no trade qualification. Valid for labouring tasks only. A green card cannot substitute for a blue card when the work requires a trade qualification — a worker on a green card should not be carrying out skilled trade work regardless of their claimed experience.
Skilled Worker (Blue card). The most common card on UK construction sites. Held by workers who have completed an NVQ Level 2 or equivalent in their trade. The card type must match the trade being carried out — a blue card for plastering does not qualify the holder to carry out electrical work. When checking a blue card, confirm that the occupation printed on the card corresponds to the actual work being performed on your project.
Academically Qualified Person (Gold card). For those with a degree or higher qualification in a construction-related discipline, plus a CSCS health and safety test pass. Primarily for site managers, project managers, and technically qualified roles where the route to competence is academic rather than trade-based.
Supervisor (Gold card). For workers at NVQ Level 3 or equivalent in a supervisory or specialist role. Both Supervisor and Academically Qualified Person cards are gold in colour — the distinction is on the card face itself. Check the card text carefully rather than accepting the colour as sufficient.
Professionally Qualified Person (Black card). For chartered professionals and those with postgraduate qualifications. Architecture, engineering, and surveying roles typically fall under this category.
Manager (Black card). For those in a management role with NVQ Level 4 or equivalent — site agent and contracts manager level. As with gold cards, two distinct card types share the same colour. Always read the card, not just the colour.
Trainee / Apprentice card. A time-limited card issued to workers who are actively working toward a qualification and have not yet achieved it. The holder must be under appropriate supervision at all times. This card is not evidence of competence in the trade — it is evidence that the holder is in training. Ensure supervision arrangements are confirmed before the worker starts.
Red Experienced Worker card (being phased out). The Red Experienced Worker card was issued to workers who could demonstrate industry experience without a formal qualification. CITB has been phasing these out — they expired at the end of their validity period and cannot be renewed. If a subcontractor presents a Red card, it has in most cases already expired. A Red card should not be accepted as valid evidence of current competence. The holder should have converted to a Blue or other appropriate card through the grandparenting process while it was available.
Visitor card. Does not qualify the holder to carry out any construction work whatsoever. A Visitor card is for escorted site visits only. Never accept a Visitor card as evidence that someone can work on site — it does not demonstrate competence in any construction role.
| Card colour / type | Qualification level | Suitable for |
|---|---|---|
| Green / Labourer | Health & safety test | Labouring tasks only — not skilled trades |
| Blue / Skilled Worker | NVQ Level 2 | Trade work matching the qualification |
| Gold / Supervisor | NVQ Level 3 | Supervisory roles |
| Gold / Academically Qualified | Degree or equivalent | Technical / professional roles |
| Black / Professionally Qualified | Chartered or postgrad | Senior professional roles |
| Black / Manager | NVQ Level 4 | Site management roles |
How to check a CSCS card is valid
The CSCS Smart Check register is at cscs.uk.com/checkcards/. Enter the registration number printed on the card and the holder's surname. The register returns the holder's name, card type, registration number, and expiry date.
What "valid" means in practice: the card is registered on the CSCS system (not merely present in someone's wallet), it has not expired, and the card type matches the role the person will be carrying out on your site. All three conditions must be satisfied. A card that is registered and unexpired but the wrong type for the work being done does not satisfy the competence duty.
If the name returned by the register does not match the person in front of you, do not proceed. A card that returns a different name is not evidence that the person presenting it is qualified. Raise it with the subcontractor — there may be a legitimate explanation such as a recent name change, but that explanation must be resolved and documented before work starts, not after.
Screenshot the CSCS register result at the point of the check. That screenshot is your evidence. Save it to the project file alongside the subcontractor's name, the registration number checked, and the date the check was carried out. This documentation is what you would produce in the event of an HSE inspection or a Building Safety Act compliance review.
One check is not permanent
A CSCS register check carried out when a subcontractor is first added to a project should be repeated if they work on subsequent projects, or if their card is approaching expiry. Card status can change — a card can be revoked or lapsed since the last time you checked. Re-check at the start of each engagement if there has been a gap of more than a few months since the previous check.
Common issues and what to do
Expired card. Work must not start until the subcontractor has renewed their card. An expired card is not evidence of current competence regardless of the holder's experience or track record. Flag it as amber — the subcontractor should be actively applying for renewal, but until a new card is confirmed on the CSCS register, they should not be on site in a skilled capacity.
Card type mismatch. A Blue Skilled Worker card for one trade is not evidence of competence in another trade. If the occupation printed on the card does not match the role the person is performing on your site, it does not satisfy the competence duty under the Building Safety Act 2022. Request the appropriate card before work starts — do not accept an assurance that the worker "can do the job" as a substitute.
"I left my card at home." The recommended site rule is zero tolerance — no card, no access. The reason is straightforward: you cannot verify a card you cannot see, and the CSCS register check requires the registration number from the physical card. A verbal assurance of competence is not a substitute. Allow access only once the card is physically available and the CSCS register check has been run and documented.
Subcontractor claims they have applied but the card has not arrived yet. CITB can confirm a registration number for cards currently in progress. Ask the subcontractor to contact CITB directly and obtain a written confirmation reference. This provides a limited basis for supervised access while the physical card is in transit — but it should be time-limited and the card check should be run as soon as the card arrives.
The Red Experienced Worker card
Many contractors are still encountering Red cards presented by older workers. These cards expired when their renewal date passed and cannot be renewed. If a subcontractor presents a Red card, check the expiry date printed on the card — if it has passed, the card is no longer valid evidence of competence. The holder should have obtained a Blue or other appropriate card through the grandparenting process while it was available. A lapsed Red card does not entitle the holder to work in a skilled trade capacity on site.
Does every person on site need a CSCS card?
Practically, yes. Most UK main contracts — residential and commercial — require a CSCS card as a condition of site access. Even where it is not a specific contract requirement, the Building Safety Act 2022 establishes occupational competence as the de facto standard for all persons working on a regulated project, and CSCS is the instrument the industry and HSE use to evidence it. The absence of a card requirement in the contract does not remove the Principal Contractor's competence duty under the Act.
Visitors and delivery drivers. A Visitor card is required for anyone accessing the site who is not carrying out construction work. They must be escorted at all times and may not perform any construction activity. A delivery driver who regularly enters the site perimeter should hold, or be issued with, a Visitor card appropriate to the level of access involved.
Specialist trades with affiliated cards. Some trades have their own affiliated scheme cards that are recognised within the CSCS framework. Gas Safe operatives, JIB-registered electricians, and EUSR-registered utilities workers carry trade-specific cards that are CSCS-affiliated and valid for the specific trades they cover. Check cscs.uk.com for the full current list of affiliated schemes — these cards are valid, but they apply only to the trade they certify. An electrician with a JIB card cannot use it to evidence competence in an unrelated trade.
Subcontractors who have no card. If a subcontractor has no CSCS card and is not in a position to obtain one quickly, they should not be on site in a role that requires one. This is not an area where commercial pragmatism should override the legal competence duty. The Building Safety Act 2022 and HSE competence guidance are clear: the Principal Contractor bears responsibility for the competence of every person on site. Allowing an uncarded worker on site to avoid a programme delay creates a documented compliance failure that may be difficult to defend.
Subchecked runs the CSCS check automatically
Registration number and surname submitted to the CSCS register. Screenshot captured as evidence. Stored immutably in your project audit trail.
Reminder
This guide is general information, not legal or tax advice. Confirm your specific obligations with a qualified solicitor or accountant.