Subcontractor Haulier Due Diligence: A Practical UK Checklist

Bought-in capacity can solve a peak, but the contracting haulier still needs to know who will carry the load, under what authority and with what insurance and competence. A saved PDF from three years ago is not an approved-supplier system.

Use proportionate onboarding, a job-specific dispatch gate and scheduled revalidation.

Map the contracting chain

Identify:

• the customer contracting with your business;
• the legal entity you appoint;
• whether that entity will operate the vehicle;
• any freight forwarder or broker involved;
• whether onward subcontracting is allowed;
• who employs or engages the driver;
• who controls route, load, site and delivery instructions.

Do not approve a trading name without the legal name, company or individual details, address and payment identity. Fraud and uninsured carriage often exploit mismatched identities.

Verify operator authority

Ask for operator-licence details appropriate to the vehicles and work. Cross-check legal entity, licence type, status, traffic area and operating centres against official Traffic Commissioner publications or services available for the check.

Confirm that a standard national or international licence is held where hire-and-reward and international work require it. A restricted licence is not a general subcontract-haulage authority.

Record check date, checker and source. Do not rely solely on a certificate sent by the supplier, and escalate spelling, entity or address differences.

Insurance must match the job

Obtain current certificates and, where needed, schedules or broker confirmation for:

• motor fleet use;
• goods in transit, including limits and exclusions;
• public and employers’ liability;
• international territory;
• high-value, temperature-controlled, hazardous or specialist goods;
• subcontracting or carriage conditions.

Insurance needs vary. Do not invent a universal minimum limit. Compare customer contract, cargo value, trading conditions and route, and obtain broker or legal advice.

Verify insurer, policyholder, dates and business activity. A certificate alone may not show exclusions that matter.

Driver, vehicle and specialist evidence

Agree what the subcontractor must verify and what your dispatch needs to see. Depending on risk:

• suitable driving entitlement and Driver CPC;
• tachograph and drivers’ hours arrangements;
• vehicle and trailer test/inspection status;
• load-security equipment and competence;
• permits and international documents;
• ADR driver, vehicle, DGSA and document arrangements;
• temperature-control capability;
• FORS, DVS or customer-site accreditation where contractually required;
• tail-lift or lifting-equipment status.

Do not collect excessive personal data “just in case”. Define purpose, access and retention.

Job-specific dispatch gate

Supplier approval does not approve every load. Before allocation confirm:

1. legal entity and named operational contact;
2. vehicle/trailer and driver assigned;
3. collection, delivery, route and time feasibility;
4. cargo, weight, dimensions and load-security needs;
5. site hazards and PPE;
6. insurance and licence scope;
7. required permits, declarations or certificates;
8. POD, tracking and exception reporting;
9. prohibition on onward subcontracting unless agreed;
10. agreed rate, waiting terms and invoicing evidence.

If the vehicle or driver changes, rerun affected checks.

Control onward subcontracting

State whether it is prohibited, permitted with written consent or allowed only within an approved network. If another carrier performs the work, you need visibility of that entity and evidence proportionate to the same risk.

A clause saying the first supplier remains responsible does not prove the actual carrier is authorised or insured.

Expiry and revalidation

Track insurance, accreditations and contractual reviews. Recheck operator status and identity periodically and after:

• ownership or legal-entity change;
• insurance renewal;
• incident, claim, prohibition or service failure;
• new specialist work;
• bank-detail change;
• extended period without use;
• information suggesting financial or compliance difficulty.

Use independent contact details to verify sensitive changes such as bank accounts.

Warning signs

• Pressure to pay a different entity.
• Licence details that do not match invoices.
• Refusal to identify the operating carrier.
• Last-minute vehicle substitution without documents.
• Insurance issued for a different activity or territory.
• Rates unrealistically below the job’s operating cost.
• Persistent missing POD or tracking.
• Requests to ignore weights, hours or site rules.
• Repeated onward subcontracting despite prohibition.

Pause allocation and escalate rather than collecting a written disclaimer.

Keep an evidence log

Record checks, source, date, result, expiry, reviewer, exceptions, approvals and jobs allocated. Retain contractual instructions and changes. Access should be controlled because files may contain personal and commercial data.

HSE contractor guidance supports co-operation and exchange of safety information. The checklist does not transfer duties between the haulier, site, driver or customer; it helps each party understand and discharge its own role.

Digital systems can keep approved suppliers and expiries visible at dispatch. They cannot verify an insurer’s coverage or make an unsuitable carrier competent.

Common mistakes

• Checking the company register but not the O-licence.
• Accepting a restricted licence for hire-and-reward work.
• Treating insurance limits as one-size-fits-all.
• Approving the company while ignoring the actual carrier.
• Allowing uncontrolled onward subcontracting.
• Collecting driver data without purpose or protection.
• Never rechecking after onboarding.
• Assuming the checklist transfers responsibility.

Frequently asked questions

Does checking an O-licence guarantee compliance? No. It confirms an important authority point at the check date. Job, vehicle, driver and ongoing controls still matter.

What insurance limit should every subcontractor hold? There is no universal answer. It depends on cargo, contract, territory and risk; use competent insurance advice.

Can a subcontractor subcontract again? Only under the agreed terms and with appropriate visibility and due diligence on the actual carrier.

How often should checks be refreshed? At document expiry, on a defined periodic cycle and after material changes or adverse events.

Who owns compliance after subcontracting? Each party retains its legal and contractual duties. A checklist or indemnity does not erase them.