CPD: Changes to the CSCS Labourer card

On 1 February 2025, the Construction Skills Certification Scheme (CSCS) introduced major changes to the length of the Labourer card. This type of card is now valid for two years on first application.

A five-year card is available on renewal to those who provide evidence of working in a labouring capacity by filling out a Labourer card renewal declaration form available from CSCS’s website or by supplying a reference from their employer/main contractor on company headed paper confirming they are working as a labourer.

At the same time, a shortened two-year Trainee card route was opened up to those who had achieved occupation-related non-competence qualifications. When the two-year card expires, the holder can gain a new three-year Trainee card by providing evidence they are registered onto an NVQ, SVQ or an agreed alternative.

This move was also designed to ensure those entering the industry start their career on a recognised training pathway – evidenced by a red card – rather than the Labourer card.

The amendments to the Labourer card are in direct response to the Building Safety Act 2022, which imposes new and more stringent requirements for competency within the construction sector.

Historically, the CSCS Labourer card has been seen by some as an easy route to gain access to construction sites, despite it being for unskilled workers not on recognised training pathways.

This has led to widespread misuse, with some workers who are not in actual labouring roles obtaining the card to bypass the requirements for more specialised skills certifications.

The total number of Labourer cards in circulation has ballooned to around 500,000. However, data from the Construction Industry Training Board’s (CITB) Construction Skills Network Forecast reveals a much lower need for labourers, with just 140,000 required annually in the coming years.

The oversupply of Labourer cards creates several problems. The most pressing of these is that individuals cannot use the card to demonstrate the skills and knowledge elements of competence that a skilled card could.

In addition, the card no longer accurately reflects the number of workers in genuine labouring roles. Furthermore, approximately 85% of labourers fail to renew their cards, and many workers leave the industry long before their cards expire.

This has led to a situation where the card is seen more as a default option for site access, rather than a mark of genuine labouring experience.

The new two-year validity period aims to better track the actual number of active labourers in the industry. After this period, workers who wish to renew their card will need to provide evidence that they are still employed in a labouring role.

This will ensure that only those actively working in genuine labouring occupations can retain the card for a longer period.

The accompanying CITB health, safety and environment test, which is a key component of the Labourer card application, will also see changes in the way it is applied. The validity of the test used for the first Labourer card will be extended from two years to three years.

This extension allows greater flexibility for those who continue in labouring roles and provides a more straightforward renewal process without imposing an undue
financial burden on workers.

By making the card’s validity period shorter and requiring proof of ongoing labouring employment, CSCS aims to create a more accurate reflection of the workforce engaged in these roles, which will allow the industry to better monitor and track the supply of labourers.

The Building Safety Act 2022 brought about significant shifts in how competency is defined and managed in the industry. It places a heavy emphasis on competence: everyone involved in construction work – from designers to contractors – must demonstrate that they have the necessary skills, knowledge, experience and behaviours for their roles.

The act requires that all construction professionals demonstrate competence for their specific roles, helping to safeguard against the risk of poor workmanship and dangerous practices.

It also establishes the framework for the ‘golden thread’ of information, a comprehensive record of all aspects of building safety, which must be maintained throughout a building’s life cycle.

The revised Labourer card rules support the drive for greater accountability by helping ensure only those in genuine labouring roles carry the card.

All CSCS Alliance card schemes are required to follow the recommendations laid out by the Construction Leadership Council (CLC), last updated in March 2024.

While labouring is currently classed as a non-skilled occupation, the recommendations state that the minimum standard for a skilled occupation must be a relevant qualification or training and testing programme that is aligned to NVQ, SVQ, IfATE Level 2 or SCQF Level 5, and that is independently verified.

The Labourer card is often seen as a quick and easy card to attain for those in non-construction occupations who can face difficulty gaining access to sites that enforce a 100% carded policy.

Those in such occupations do not need CSCS cards. The recommendations also highlight that “cards will not be issued for non-construction related occupations or those visiting sites”.

By making these changes, CSCS aims to align the Labourer card more closely with broader industry goals including improving safety on sites and ensuring compliance with regulations such as the Building Safety Act.

Garry Mortimer is executive director of operations at CSCS Cards.

Wood Wharf is a transformative 9ha mixed-use development in the heart of Canary Wharf, east London, where the project’s site management team is reaping the rewards of using CSCS Smart Check to verify workers’ cards and credentials.

Ensuring individuals have the right card for their role is also a prerequisite at this project.

Central to its health and safety strategy is the digital verification of CSCS-logoed cards using CSCS Smart Check.

Cards carrying the CSCS logo from across the CSCS Alliance ensure that over two million workers in construction and the wider built environment are properly trained and qualified for the job they do on site.

Monima Harrison, director of health, safety and wellbeing at Canary Wharf Group, one of the companies behind the scheme’s development, emphasises the importance of having “the right card for the right job”.

Trevor Simpson, health and safety manager and Unite the Union representative, who conducts site inductions at Wood Wharf, says: “We’re very stringent because we want to do the job once and do it right.”

This approach means only workers with the appropriate qualifications and training can carry out works in the project.

Simpson adds that the CSCS Smart Check technology has made a “massive difference” at Wood Wharf.

He says: “To have the right card for the job is crucial because we know that they’re understanding the job role and they’ve been assessed. We won’t accept people coming through, for instance, on a Labourer card to do a trade.

“It’s also about protecting the trades. [Workers are] very protective, they’ve done a lot of work, they’ve gone through apprenticeships and so on to be able to gain their qualifications to do the jobs. If you allow anybody to come in on a Labourer card to do that job, all you’re doing is devaluing that trade.”

While initial resistance existed from some contractors accustomed to less stringent checks, the benefits of digital verification extend beyond compliance. Simpson advises other construction sites to adopt CSCS Smart Check, stating: “Make sure you are checking cards rigorously.”

With the Building Safety Act mandating that all individuals in construction roles must be able to demonstrate their competence through the appropriate skills, knowledge, experience and behaviours, CSCS Smart Check can play a key role in helping ensure compliance.

Watch the case study video at CSCS.uk.com/WoodWharf.