BS 10119 Readiness Checklist: Are You Ready for Your Labour Provision Audit?

Use this 25-point bs 10119 checklist to test your firm against BS 10119:2026 before you book a formal labour supply audit. Score 1 point for each “Yes” backed by clear written proof across our nine audit areas. These areas cover leadership rules, SIA licence checks, BS 7858 screening, right to work checks, PAYE pay, working time, staff training and PPE, second-tier suppliers, and records. Score 0 points for any “No” or missing proof. A score of 21–25 shows strong audit readiness, 15–20 highlights gaps you can fix, and under 15 means you should start with a structured gap review before you contact an audit body.

This self-assessment tool is written for directors, compliance leads, and operations managers at UK labour providers. It helps firms that supply guards, door supervisors, stewards, and support staff to the security, crowd management, events, and facilities sectors. You may be moving from the Security Industry Authority (SIA) Approved Contractor Scheme (ACS) Code of Practice (COP 119 labour provision compliance hub). Or you may be planning a standalone British Standards Institution audit. Pair this checklist with our complete BS 10119 guide and our COP 119 compliance guide to make sure your staff files will pass live audit checks.

In this guide

• How do you score your BS 10119 readiness and what does the checklist cover?
• What are the 25 questions in our BS 10119 requirements and labour provider audit checklist?
• How does your BS 10119 readiness score translate into next steps before a BS 10119 audit?
• What are the five gaps that most often fail a BS 10119 audit?
• Pre-audit evidence pack: what documents must be on your desk?
• Frequently asked questions

How do you score your BS 10119 readiness and what does the checklist cover?

To measure your bs 10119 readiness well, use the same strict rule that external auditors apply during document checks and live file reviews. Give yourself 1 point (“Yes”) only when you have a written policy and you can show consistent live records proving that your team follows it on every shift. If a process is informal, only partly in place, or missing from your staff files, give yourself 0 points (“No”).

BS 10119 sets a clear national standard for firms that supply security guards, door staff, stewards, and response teams. It builds on the vetting, tax, and pay rules set out under SIA ACS COP 119. This gives buyers, main contractors, and UK bodies—such as the Home Office, HMRC, the Security Industry Authority, and the Care Quality Commission (CQC) where staff work in regulated health or social care settings—clear proof that supplied staff are legally employed, vetted, and trained for their role.

How to use this checklist for board and pre-audit review: Work through all 25 questions below with your HR, payroll, and operations leads, or print this page as a working audit sheet. Only award a point where you can open a live staff or payroll file on your desk today and show documentary proof.

What are the 25 questions in our BS 10119 requirements and labour provider audit checklist?

Work through all nine parts of this labour provider audit checklist in order. Keep a count of each question where you can show clear written proof today. Because the standard brings together UK employment law and security screening, this tool also works as your day-to-day cop 119 checklist if you hold or want to gain SIA Approved Contractor status.

1. Organisation and responsibilities (Questions 1–3)

Auditors start by checking that company directors take active control of labour supply rules rather than leaving compliance to chance. Under Section 23 of the Private Security Industry Act 2001, directors and senior officers can face personal criminal liability when offences occur with their consent, connivance, or neglect.

• Q1. Named statutory compliance owner (Yes = 1 / No = 0): Have you named a company director or senior manager with clear written authority over bs 10119 requirements? Does this person oversee SIA licensing, HMRC PAYE tax rules, and Home Office right to work checks?
• Q2. Scope, insurance, and SLA clarity (Yes = 1 / No = 0): Do you hold signed client contracts and service level agreements (SLAs) for every labour supply job? Do these agreements set out screening rules, site management duties, and public and employers’ liability insurance cover?
• Q3. Financial and regulatory due diligence (Yes = 1 / No = 0): Can you show up-to-date company records and clear proof that your VAT and PAYE payments to HMRC are on time? Do you also hold a written business continuity plan that covers sudden staff shortages or licence issues?

2. SIA licence control (Questions 4–6)

Under the Private Security Industry Act 2001, Section 3 bans licensable conduct without a valid licence, while Section 5 makes it a criminal offence to supply or use an unlicensed security operative. Schedule 2 sets out controlled activities, including manned guarding, keyholding, and door supervision at pubs, clubs, and similar venues.

• Q4. Pre-deployment SIA Register verification (Yes = 1 / No = 0): Do you check each worker’s SIA licence status, licence number, expiry date, and licence sector (such as manned guarding, door supervision, or keyholding) on the official SIA Register of Licence Holders before their first shift?
• Q5. Ongoing automated or scheduled monitoring (Yes = 1 / No = 0): Do you run and log regular scheduled checks against the SIA Register of Licence Holders? Would your system spot a revoked, suspended, or modified licence under Sections 8 to 12 of the Act before a guard is booked onto a shift?
• Q6. Licensable vs non-licensable role boundary controls (Yes = 1 / No = 0): When you supply event stewards alongside licensed security guards, do you keep clear deployment plans? Can you prove that stewards never carry out licensable duties listed under Schedule 2 of the Private Security Industry Act 2001?

3. BS 7858 screening and vetting (Questions 7–9)

Security staff supplied under BS 10119 must be vetted in line with BS 7858 screening rules. The SIA also prosecutes individuals who provide fake references, making independent reference verification vital for every labour provider.

• Q7. Continuous career and residence trail (Yes = 1 / No = 0): Does every screened worker file hold independent written proof of employment, study, self-employment, or time out of work for the full BS 7858 screening period? Have you checked and recorded the reason for every career gap in that history?
• Q8. Identity, criminality, and financial probity checks (Yes = 1 / No = 0): Do you complete identity checks, financial background and public record searches, and criminal record checks for every security operative before you sign off their full BS 7858 screening file?
• Q9. Strict conditional employment time limits (Yes = 1 / No = 0): When staff start work on conditional screening under BS 7858, does a senior manager sign a written risk assessment first? Are baseline checks done before shift one, and is full screening finished within the allowed BS 7858 time limit?

4. Right to work checks (Questions 10–12)

The Home Office guide, Right to work checks: an employer’s guide (updated 1 October 2026 by UK Visas and Immigration and Immigration Enforcement), sets out what employers must do to prevent illegal working in the UK before employing anyone.

• Q10. Statutory excuse obtained before day one (Yes = 1 / No = 0): Do you complete a compliant right to work check for every worker before they start work? Do you use acceptable documents for a manual check, a certified Identity Service Provider (IDSP) digital check, or a Home Office online check?
• Q11. Timestamped verification and copy retention (Yes = 1 / No = 0): Does every right to work file hold clear copies, work conditions, and the exact date on which the check was made? Do your staff know that expired physical Biometric Residence Permits (BRPs) are not acceptable proof of right to work?
• Q12. Follow-up checks and Employer Checking Service verification (Yes = 1 / No = 0): Do you diarise follow-up checks for workers with time-limited permission to work in the UK? Where a worker has an outstanding Home Office application made before their previous leave expired, or an outstanding appeal, do you obtain a Positive Verification Notice from the Employer Checking Service (ECS)?

5. Employment status, PAYE and pay (Questions 13–15)

A core aim of both COP 119 and BS 10119 is to stop false self-employment, unapproved pay intermediaries, and unlawful pay deductions in security and events labour supply chains.

• Q13. Direct PAYE employment as the default model (Yes = 1 / No = 0): Are all supplied staff paid directly on your own PAYE payroll with tax and National Insurance reported to HMRC? If any specialist contractor is ever engaged outside direct PAYE, do you hold a clear written employment status assessment?
• Q14. Clear written employment documentation before work starts (Yes = 1 / No = 0): Do all temporary and contract staff receive clear written employment documentation before they agree to work? Does this paperwork show their pay rate, pay intervals, deduction rules, notice terms, and holiday entitlement clearly?
• Q15. Statutory minimum pay and holiday pay compliance (Yes = 1 / No = 0): Do your payroll checks confirm that uniform costs, SIA licence fees, or mandatory training hours never push hourly pay below the legal minimum wage? Is statutory holiday pay properly calculated, accrued, and paid on time?

6. Working time and rest breaks (Questions 16–18)

Tired guards and stewards create serious health, safety, and security risks on client sites. Auditors check your shift logs and timesheets to make sure your scheduling system protects worker health and well-being.

• Q16. Weekly working hours and voluntary opt-out register (Yes = 1 / No = 0): Do you track average weekly working hours for every supplied worker across all sites? Where staff choose to work above standard weekly limits, do you hold signed, voluntary opt-out forms that they can cancel at any time?
• Q17. Daily rest, weekly rest, and break enforcement (Yes = 1 / No = 0): Does your booking software block back-to-back shifts that cut into daily rest between duties or weekly rest days? Do your site rosters also make sure guards get proper rest breaks during long shifts?
• Q18. Night worker health assessments (Yes = 1 / No = 0): Do you offer free, private health assessments to all staff who regularly work night shifts? Do you offer these checks before they start night duties and at regular intervals after that, and keep clear logs?

7. Training, competence and PPE (Questions 19–21)

Holding an SIA licence alone does not prove a worker is ready for every site. The SIA monitors licence-linked qualifications, tackles training malpractice, and prepares the industry for Martyn’s Law, while CQC fundamental standards apply when staff work in regulated health and social care settings.

• Q19. Site-specific induction and assignment instructions (Yes = 1 / No = 0): Do you check and record that every supplied worker gets a full site induction before starting at a new venue? Does this cover fire exits, incident reporting, and written assignment instructions?
• Q20. Specialist role and conflict management competence (Yes = 1 / No = 0): Do you check that qualifications come from legitimate training providers? When staff work at public venues preparing for Martyn’s Law or at CQC-regulated NHS trusts, urgent care, or mental health sites, do you log role-specific training proof?
• Q21. Free issue and replacement of PPE (Yes = 1 / No = 0): Do you give workers all needed personal protective equipment—such as high-visibility vests, safety boots, or protective gear—free of charge? Do you keep signed issue sheets and never take PPE deposits from wages?

8. Second-tier suppliers and subcontracting (Questions 22–23)

Passing shifts to another labour agency without client knowledge is one of the fastest ways to fail a BS 10119 or SIA ACS audit. Supply chain compliance requires strict control over every tier.

• Q22. Prior written client approval for any subcontracting (Yes = 1 / No = 0): Do your company rules ban passing work to a second-tier labour supplier unless you first get clear written permission from the end client for that named supplier?
• Q23. Second-tier supplier BS 10119 / COP 119 equivalence audits (Yes = 1 / No = 0): Before you use any secondary supplier, do you check their approvals and audit a live sample of their staff files? Do you check their BS 7858 screening, SIA licences, right to work records, and PAYE pay proofs yourself?

9. Records, data protection and audit evidence (Questions 24–25)

If an auditor cannot find your records quickly during a remote or on-site check, that item will fail. BSI standards place strong weight on information security, data privacy, and quality management.

• Q24. Data privacy security and retention schedules (Yes = 1 / No = 0): Are staff vetting files, right to work copies, and payroll logs stored in secure, access-controlled systems? Do you follow a clear privacy and data retention schedule that sets out when records must be kept and securely deleted?
• Q25. Quarterly internal audits and management review (Yes = 1 / No = 0): Do you run and record internal self-audits against BS 10119 rules at least once a quarter? Do company directors review the findings and sign off every corrective action once it is fixed?

How does your BS 10119 readiness score translate into next steps before a BS 10119 audit?

Add up your total score out of 25 and check your result against Table 1 below. Your score shows whether you are ready to book your external assessment now or should fix file gaps first with BS 10119 consultancy support.

Band 1: Scoring 21–25 points (Ready for pre-audit sampling)

A score of 21 or above shows that your core labour supply systems are working well. Your direct PAYE payroll, pre-shift right to work checks, live SIA licence logs, and BS 7858 screening files are in good shape. Still, do not assume a score of 22 out of 25 means an automatic pass if your three missed points sit in legal red-line areas like Questions 4, 10, or 13. Before you confirm your audit dates, pull a fresh sample of new starters. Make sure every conditional BS 7858 file has a signed risk assessment and every time-limited right to work file has a clear follow-up check date.

Band 2: Scoring 15–20 points (Addressing operational gaps before booking)

Many growing security and event labour providers score between 15 and 20 on their first check. Often, their written policies look fine on paper, but busy event peaks leave gaps in career reference chasing, working time opt-out logs, or site induction records. Booking an external audit while in this band is a costly mistake. If an assessor finds repeated screening delays or undated right to work copies during live sampling, they will log a major non-conformity. You will then have to prove root-cause fixes and pay for a repeat audit visit.

Band 3: Scoring under 15 points (Why you must start with a structured gap analysis)

If you score under 15, your firm faces commercial and legal risks that go well beyond British Standards approval. Using unverified pay intermediaries, paying flat shift rates off-payroll, or sending guards to site before completing a Home Office right to work check can lead to HMRC tax demands, Home Office enforcement action, or loss of SIA Approved Contractor status. Start by booking a free initial consultation. A lead auditor can map out a step-by-step fix plan covering staff contracts, screening workflows, and audit logs.

What are the five gaps that most often fail a BS 10119 audit?

Across the UK security and crowd management sector, five common errors cause most failed or delayed audits. Check these five risk areas carefully before you finish your bs 10119 audit prep.

1. Off-payroll intermediaries and false self-employment: Supplying security guards or stewards through unverified pay schemes, false self-employment, or opaque intermediaries is the top reason audits fail on day one. Assessors match your shift rosters directly against your HMRC PAYE payroll records and bank statements. They check that every supplied hour goes through compliant PAYE payroll.
2. Incomplete BS 7858 screening and unverified references: BS 7858 allows conditional employment only when baseline identity, right to work, criminal record, and initial career checks are in place and a manager signs a risk assessment. Providers fail audits when staff stay on provisional status too long, when career gaps are ignored, or when references are not checked independently. Note that the SIA actively prosecutes individuals who submit fake references.
3. Defective right to work checks and expired physical BRPs: Holding an undated passport scan fails the Home Office Right to work checks: an employer’s guide. As the Home Office guide clarifies, expired physical Biometric Residence Permits (BRPs) are not acceptable proof of right to work. Employers also fail audits when they miss follow-up checks on time-limited leave or fail to get a Positive Verification Notice from the Employer Checking Service (ECS) for an outstanding application or appeal.
4. One-off SIA licence checks without ongoing register monitoring: Checking a guard’s SIA badge only on the day they join is not enough for BS 10119. Under the Private Security Industry Act 2001, the SIA can revoke, suspend, or add conditions to a licence at any time, and using an unlicensed operative is an offence under Section 5. If your team only tracks expiry dates and misses a mid-contract revocation on the SIA Register, you will fail the check.
5. Informal shift-filling through unvetted second-tier agencies: When an event or retail contract spikes at short notice, managers sometimes borrow guards from a local firm. If that second-tier supplier has not been approved in writing by your client and audited by your team against every point on this bs 10119 checklist, your own approval is put at risk.

Pre-audit evidence pack: what documents must be on your desk?

Before your external assessor visits your office or logs into your portal for a remote check, set up a clear digital audit room with these eight master folders:

• Folder 1 – Corporate Governance & Quality Manual: Signed BS 10119 and COP 119 policy, org chart naming the compliance director, company registration filings, and employers’ and public liability insurance certificates.
• Folder 2 – Client Contracts & SLA Register: Signed labour supply contracts setting out vetting rules, charge rates that cover statutory pay and holiday costs, and clear rules on subcontracting.
• Folder 3 – Master Active Operative Roster: Full spreadsheet export of all staff supplied over the past year. Show start date, PAYE status, SIA licence number, licence sector, expiry date, BS 7858 sign-off date, and right to work check date.
• Folder 4 – Right to Work & Follow-Up Controls: Sampled right to work files, IDSP service agreements, follow-up check diary for time-limited leave, and any Positive Verification Notices from the Home Office Employer Checking Service.
• Folder 5 – BS 7858 Vetting Files: Complete screening files with career history proof, gap checks, financial and public record searches, criminal record checks, and signed conditional employment risk assessments.
• Folder 6 – HMRC PAYE, Minimum Wage & Holiday Pay Reconciliations: Recent HMRC PAYE payroll submissions, tax payment receipts, written employment documentation, itemised payslips, and holiday pay accrual logs.
• Folder 7 – Operations, Working Time & PPE Logs: Shift rosters showing rest periods between shifts, signed weekly working time opt-out forms, night worker health check records, site induction logs, and signed free PPE issue sheets.
• Folder 8 – Second-Tier Supplier & Internal Audit File: Approved subcontractor list, written client consent letters, completed tier-2 supplier audit checklists, and your recent quarterly internal BS 10119 audit reports with signed-off fixes.

Frequently asked questions

What does BS 10119 cover?

BS 10119 covers how firms manage, screen, employ, and supply staff into the UK security and events sectors. It sets clear, auditable rules across nine areas: leadership duties, SIA licence checks, BS 7858 background screening, Home Office right to work checks, direct PAYE employment and statutory pay, working time and rest controls, role training, free PPE issue, second-tier supplier checks, and secure record-keeping.

How do I prepare for a BS 10119 audit?

Start by scoring your firm against our 25-point checklist and checking a random sample of five to ten live worker files. Match your shift rosters against your HMRC PAYE payroll records to prove all staff are paid properly on payroll. Check that every conditional BS 7858 file has a signed risk assessment, confirm every worker has a dated right to work check and active SIA licence log, and run an internal mock audit before booking your assessment.

Is the BS 10119 checklist the same as COP 119?

Both frameworks cover the same day-to-day compliance controls, though they started in different ways. COP 119 (Code of Practice for the Provision of Labour in the Security and Events Sectors) was created to govern labour providers inside the SIA Approved Contractor Scheme (ACS). BS 10119 builds those core principles into a formal British Standard published by BSI. If your records pass our 25-point bs 10119 checklist, they will also meet the core audit demands of COP 119.

How long does it take to get BS 10119 certified?

Timeframes depend on how clean your current staff and payroll files are. A labour provider that already pays all staff on direct PAYE and runs full BS 7858 screening can prepare its quality records and complete the audit process quickly once several months of clean records are ready. If you score under 15 and need to move staff onto direct PAYE or close historic screening gaps, allow extra time to build consistent live records before your audit.

Can a labour provider use subcontractors under BS 10119?

Yes, but only under strict, auditable rules. You must get clear written permission from your end client before you deploy any second-tier labour supplier. You also stay fully responsible for proving that the subcontractor meets every BS 10119 rule—including direct PAYE payroll, Home Office right to work checks, SIA licence checks, and BS 7858 screening—backed by your own documented supplier audits.

Sources: BSI Group (BS 10119 & BS 7858 Standards); Security Industry Authority (SIA ACS & Register of Licence Holders on GOV.UK); Home Office Employer’s Guide to Right to Work Checks (GOV.UK); Private Security Industry Act 2001 (legislation.gov.uk); Care Quality Commission (CQC Guidance and Regulation). Last checked: October 2026.