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Small GC Compliance Guide

If you're running a small general contracting operation — under 50 employees, maybe a handful of regular subs — you don't need an enterprise compliance program. But you do need a system. This guide covers exactly what to track, and how to do it without a dedicated compliance team.

The compliance problem for small GCs

Large GCs have compliance departments. Small GCs have you — or a project manager wearing six hats. The problem isn't knowing what compliance requires. It's that it takes time you don't have, so it slips. And the thing that slips is usually a subcontractor's COI or license renewal — right before something goes wrong.

What you actually need to track

Compliance for a small GC comes down to three categories of documentation for every subcontractor:

Insurance (COI)

Every sub needs a current Certificate of Insurance on file. At minimum: General Liability and Workers' Comp. Your organization should be named as additional insured on the GL policy.

The catch: COIs expire — typically annually. Most small GCs collect them at onboarding and forget about them. Set a calendar reminder or use software to alert you 30–45 days before expiration.

State Contractor License

Not all trade work requires a state license, but when it does, it has to be current and active. The license type also has to match the work — a plumbing license doesn't cover electrical.

Verify status directly in the state database — don't accept a copy
Log the license number, type, and expiration date in your records
Re-verify before any new project starts — status can change between jobs

W-9 (Tax Document)

Collect a signed W-9 before issuing any payment to a sub you'll pay $600 or more in a year. You need the EIN or SSN for 1099-NEC filing. Verify the entity name on the W-9 matches the contract and license.

Note: W-9s don't expire technically, but if a sub changes their business structure or EIN, you need a new one. Request updates annually or when anything about their business changes.

Building a system that doesn't break down

The goal isn't a perfect compliance program — it's a system that doesn't depend on someone remembering to check things. Here's the minimum viable version:

Create a vendor file for every sub

One place: license number + expiration, COI PDF + expiration, W-9 on file. Doesn't matter if it's a folder in Google Drive, a spreadsheet, or software — just one place.

Set expiration alerts

COI and license expirations are the things that slip. Set a calendar reminder 45 days out from every expiration. That gives you time to follow up before the policy lapses.

Verify before each new project

Even trusted subs can have lapses. A 2-minute license check before a new project starts is worth 20 hours of insurance dispute later.

Collect W-9s at onboarding, before first payment

Don't wait until January. By then you've already paid them, they've moved on, and you're scrambling for paperwork during tax season.

Keep a "noncompliant" flag

If a sub's COI expires and they haven't sent a renewal, mark them inactive until it's resolved. This is the step most small GCs skip — and the one that protects you.

The most common compliance mistakes small GCs make

Assuming a trusted sub is always compliant

Long relationships don't prevent license suspensions or insurance lapses. Verify on a schedule, not on trust.

Accepting a license photo as proof of current status

A photo of a license doesn't prove it's still active. State databases take minutes to check.

Collecting COIs at onboarding and never again

Insurance renews annually. The COI you collected 14 months ago is expired. Most small GCs don't realize this until they need to file a claim.

Waiting until tax season to collect W-9s

You need the W-9 before payment, not after. Chasing them in January adds unnecessary friction.

Treating all trades the same

Electrical, plumbing, HVAC, and general labor have different licensing requirements by state. A compliant sub for one trade may be unqualified for another.

When a spreadsheet stops being enough

A spreadsheet works fine at 5–10 subs. At 20+, the manual maintenance becomes its own job. Signs it's time to move to purpose-built software:

You've had a sub on a job with an expired COI and didn't know until after
You're spending more than 30 minutes per week checking statuses manually
Your sub roster changes frequently (new subs per project)
A GC, owner, or insurance carrier has asked you for a compliance report
You have multiple project managers who each need to see sub compliance status

Built for small GCs who don't have a compliance team

TrackMyVendor tracks license status, COI expiration, and W-9 status automatically — and sends alerts before anything lapses. Most teams are set up in under 30 minutes.

Start free trial Run a free compliance assessment

Related resources

5-Minute Contractor Verification Checklist

Quick check before any sub starts work

General Contractor Insurance Requirements

Coverage minimums and requirements by project type

How to Track Subcontractor Compliance

Build a system that scales as you add more subs

COI Tracking Spreadsheet (free)

Free template to start tracking COIs immediately