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Compliance checklist

Subcontractor Compliance Checklist: COIs, W-9s, Lien Waivers, and Renewal Dates

What you need to collect from every subcontractor, which fields actually matter, and how to know at a glance whether a sub is ready to work, needs follow-up, or is blocked.

Why compliance paperwork keeps slipping

The problem is not that GC offices do not know what they need. Most project managers can recite the list: certificate of insurance, W-9, license if the trade requires it, lien waivers on the payment cycle. The problem is that "collected" and "current" are two different things, and nobody has a clean way to see which is which.

A certificate arrives as a PDF attachment. Someone saves it. The row in the spreadsheet gets updated. Six months later the policy expired and nobody set a reminder. A W-9 was collected at onboarding three years ago and the sub's address changed twice. A lien waiver is sitting in someone's email waiting to be countersigned.

The checklist below is not about collecting more paperwork. It is about knowing the status of the paperwork you already asked for.

The core compliance documents — what to track for each

Certificate of Insurance (COI)

This is the highest-urgency document because it expires, and an expired COI is a job-site liability. For each subcontractor, track:

Field	What to record	Why it matters
GL expiration date	MM/DD/YYYY from the certificate	Drives renewal reminders
WC expiration date	MM/DD/YYYY or "exempt" with reason	Often different from GL
Umbrella expiration date	MM/DD/YYYY or "not required"	Required on many larger jobs
GL limit on file	$1M/$2M or whatever the cert shows	Must meet contract minimums
Certificate holder	Your company name as listed on cert	Wrong name = not your cert
Additional insured	Yes / No / Per contract	Required for most GC contracts
Status	Current / Expiring <60 days / Expired / Missing / Needs review	Action at a glance
Certificate file location	Link or folder path to saved PDF	Instant retrieval when owner asks
Last reviewed by	Name or initials and date	Accountability and audit trail
Next reminder date	60 days before earliest expiration	Triggers follow-up before it lapses

W-9

The W-9 is a one-time collection for most subs, but it has a way of going stale. An address change, a business name change, or a change in tax classification should prompt a new request.

Field	What to record
W-9 received	Yes — date received / No — request pending
Business name on W-9	Must match name on checks and contracts
TIN type	SSN or EIN
Date received	MM/DD/YYYY
Needs update	Flag if sub's info has changed since last W-9
File location	Path or link to signed PDF

For 1099 purposes, your accounting team will need the W-9 on file before payment. If it is missing, payment should be held or backup withholding applies. That is a strong motivator to collect W-9s at onboarding, not after a problem surfaces.

Contractor's License

Not every sub in every state requires a license, but where they do, an unlicensed sub working on your job is your exposure too. Track:

Field	What to record
License required	Yes / No — based on trade and jurisdiction
License number	As issued
Issuing authority	State, county, or city
Expiration date	MM/DD/YYYY
Status	Active / Expired / Pending renewal

Lien Waivers

Lien waivers are project-specific and payment-cycle-specific, which makes them harder to track in a single-row-per-sub format. Track them by project and payment event:

Field	What to record
Project name / number	Ties to specific job
Waiver type	Conditional / Unconditional, Partial / Final
Payment amount covered	Dollar amount from the pay app
Date requested	When you sent the request
Date received	When signed waiver came back
Status	Requested / Received / Countersigned / Filed
File location	Path or link

Most GC offices manage lien waivers through their accounting or project management system rather than a COI tracker. The important thing is that they are tracked somewhere with a clear status, not floating in email.

Safety and Prequalification Documents

OSHA training records, safety plans, or prequalification forms are only required on certain job types — owner requirements, public jobs, or larger commercial work. If your jobs require them, add a simple row to your compliance file:

Field	What to record
Document type	OSHA 10, OSHA 30, safety plan, prequalification form, etc.
Required for this job	Yes / No
Received	Yes / No — date
Expiration if applicable	Training certificates expire; plans typically do not

The status system that keeps the checklist usable

Every document type should have a status your team can read without opening the file:

• Current — received, reviewed, not expiring in the next 60 days
• Expiring soon — less than 60 days to expiration, renewal request sent or pending
• Expired — past expiration date, work may be blocked
• Requested — asked for but not received yet
• Missing — required document, no request sent or no response
• Needs review — received but something does not match requirements
• Not required — document type does not apply to this sub or job

The "not required" status matters. If it is blank, you cannot tell whether the document was never needed or was never collected.

Assigning ownership and follow-up responsibility

Compliance fails when every document is "the team's job." For each document category, name one person who owns the request, review, and follow-up. That does not mean they do all the work — it means they are accountable for knowing the status.

For most small and mid-size GC offices, the office manager or project coordinator owns COIs and W-9s. Project managers own lien waivers by job. Safety documents may fall to a superintendent or a dedicated safety coordinator if one exists.

Write the owner into the checklist. "Who's handling this?" answered in a cell means one less conversation per renewal cycle.

A first-pass checklist for this week

You do not need to build a perfect compliance system in one sitting. Start with three columns on your active sub list:

1. Latest COI expiration date (or "missing" if you cannot find one)
2. W-9 on file (yes / no)
3. Biggest open gap for each sub (lien waiver outstanding, license expired, etc.)

If assembling that list takes more than a day or reveals more missing documents than you expected, the compliance workflow has more gaps than the current system is surfacing. That is useful to know. Fixing it starts with knowing where the holes are, not with building a new process before you understand the old one.

A good compliance checklist does not require perfection. It requires honest status. "Missing" and "needs review" are acceptable answers — "I'm not sure" is the problem.

Keep reading

• Weekly subcontractor COI tracking workflow
• COI renewal reminder email templates