Is Your Subcontractor Actually Licensed? Here's How to Check in Ten Seconds

A subcontractor invoices you for plumbing, electrical, or building work. They have an ABN, a registered company, an active GST registration — every check passes. None of that confirms they are legally allowed to do the work they just billed you for.

Trade licensing is a separate regime entirely, run state-by-state, and it is the check most accounts payable teams never think to run because it does not show up in the standard ABN/ASIC checks at all.

Why a Licence Check Is a Different Question

ABN registration and ASIC company registration confirm an entity exists and is allowed to trade in general. They say nothing about whether that entity is licensed to perform a specific regulated trade — electrical work, plumbing, building, gasfitting. In Queensland, the QBCC (Queensland Building and Construction Commission) licenses builders and trade contractors. In NSW, the equivalent function sits with NSW Fair Trading's contractor licence register. Each state runs its own scheme, with its own licence classes, renewal cycles, and suspension/cancellation processes.

A company can be a perfectly valid, GST-registered, ASIC-compliant entity and still have a lapsed, suspended, or never-issued trade licence. Engaging an unlicensed contractor for licensable work carries real exposure: insurance complications if something goes wrong on site, exposure under state building legislation, and — for principal contractors — potential liability for engaging unlicensed subcontractors on a project.

What the Check Actually Looks Up

Gumshoe's licence check matches the entity against the QBCC licence register (Queensland) and the NSW Fair Trading contractor licence register by ABN and entity/trading name. Where a match is found, the result surfaces the licence number, licence class, and current status — active, suspended, cancelled, or expired — along with the source register so you can verify independently.

Where no match is found, the result is NA rather than FAIL. A huge number of legitimate businesses — office cleaners, IT contractors, professional services firms — have no reason to hold a trade licence at all. The check is only meaningful for entities actually performing licensable trade work, which is why it sits in the opt-in tile set rather than the default checks: you turn it on when you are verifying a tradie or construction subcontractor specifically.

The Construction-Specific Pattern

Licence status rarely fails in isolation. In Gumshoe's broader register sweep, an expired or suspended licence frequently co-occurs with other warning signs: a director appearing on the insolvency register from a previous entity, a domain registered within the last 180 days alongside an ABN that is much older (suggesting a recent rebrand after a prior business folded), or active disqualification under the ASIC banned persons register. None of these signals is conclusive on its own. Together, they describe a recognisable pattern — a contractor who has been here before, under a different name, and did not leave in good standing.

This is exactly the kind of cross-register pattern the phoenix activity check is built to surface, and it is why the licence tile is most valuable when run alongside insolvency, banned-persons, and director history checks rather than in isolation.

What's Next: More States

QLD and NSW between them cover a large share of Australia's licensed trade workforce, but Victoria, WA, and South Australia each run their own equivalent registers and are not yet covered. If you operate primarily outside QLD/NSW, the licence check will correctly return NA for entities licensed only in your state's register — this is a coverage gap, not a false negative, and it is the next register expansion on the roadmap.

Add the licence check next time you verify a construction subcontractor or trade supplier. If their licence is active, you have a documented record of it at the moment you engaged them — which matters if the question ever comes up later.

Uncommon Insights

Under section 56 of the Queensland Building and Construction Commission Act 1991 (QBCC Act), engaging an unlicensed contractor for licensable work can result in significant financial liability, including the possibility of having to pay damages or compensation to affected parties. Furthermore, the QBCC may also impose administrative penalties under section 72 of the QBCC Act, which can be substantial. It is crucial to verify the current status of a subcontractor's licence, rather than just its existence.

ASIC's registers do not capture trade licensing information, which is a critical gap in accounts payable checks. ASIC's role under the Corporations Act 2001 (Cth) is to maintain a register of companies and business names, but it does not extend to trade licensing, which is a state-based regime. Therefore, relying solely on ASIC checks can create a false sense of security, as a company can be registered with ASIC but still be unlicensed to perform specific trade work.

Section 18 of the Australian Consumer Law (ACL) prohibits engaging in conduct that is misleading or deceptive. If a subcontractor misrepresents their licensing status or fails to disclose that their licence is suspended or expired, this could be considered a breach of the ACL. Principal contractors and project managers should be aware of this risk and take steps to verify the licensing status of their subcontractors to avoid potential liability.

The ATO's Taxation Administration Act 1953 (Cth) requires entities to be registered for GST if they carry on an enterprise and their annual turnover is $75,000 or more. However, GST registration does not confirm that an entity is licensed to perform specific trade work. In fact, many unlicensed contractors may still be registered for GST, which can create a false sense of legitimacy. Verifying a subcontractor's licence status is essential to ensure compliance with state-based trade licensing regimes.