TrackMyVendor Resources AZ Subcontractor License Requirements for GCs

Compliance Guide · Arizona

Arizona Subcontractor License Requirements: What GCs Must Verify Before Work Starts

Arizona licenses every contractor — general and specialty — through the Registrar of Contractors. CR-11 for electrical, CR-37 for plumbing, CR-42 for roofing. Here is what general contractors must verify before any sub begins work.

8 min read Updated May 2026 Written for general contractors

How Arizona Contractor Licensing Works

Arizona is one of the most comprehensive contractor licensing states in the country. The Arizona Registrar of Contractors (ROC) issues licenses to all contractors — general and specialty — under Arizona Revised Statutes Title 32, Chapter 10. Working without an active ROC license is a criminal offense.

The ROC uses a prefix-based classification system. General contractors hold A (engineering), B (residential), B-1 (commercial), B-2 (small commercial), or KB (dual commercial + residential) licenses. Specialty trades hold C- (commercial), R- (residential), or CR- (dual) license codes followed by a number identifying the specific trade.

Every ROC license requires an active surety bond, proof of workers' compensation insurance, and a qualifying individual — the person whose experience and exam results support the license. If the qualifying individual leaves the company or the bond lapses, the license automatically goes inactive. Inactive status means the contractor cannot legally perform work.

License status can change between contracting and mobilization. If a sub's surety bond lapses — even temporarily — the ROC automatically places the license in inactive status. A license that was active when you signed the subcontract may be inactive by the time the sub steps on site. Always re-verify immediately before work begins.

ROC License Codes by Trade

The CR- prefix indicates a dual license valid for both commercial and residential work — the most versatile and common type for subcontractors. Verify that the license code on the sub's ROC record matches the type of work they will perform. A CR-67 low-voltage license does not authorize CR-11 electrical work.

Trade ROC license code Notes
Electrical CR-11 (dual), C-11 (commercial), R-11 (residential) Full electrical installation, alteration, and repair. Mandatory for any electrical sub. 16 hours CE required every 2 years.
Plumbing CR-37 (dual), C-37 (commercial), R-37 (residential) Installation, alteration, and repair of plumbing systems.
HVAC / Air Conditioning CR-39 (dual), C-39 (commercial), R-39 (residential) HVAC installation and repair. Federal EPA 608 refrigerant certification is also required for technicians handling refrigerants.
Roofing CR-42 (dual), C-42 (commercial), R-42 (residential) Full roofing installation and repair. One of the most commonly verified specialty codes.
Fire Suppression CR-16 (dual), C-16 (commercial), R-16 (residential) Fire sprinkler system installation and repair. R-16 scope is limited to one- and two-family dwellings under three stories.
Low Voltage / Communications CR-67 (dual), C-67 (commercial), R-67 (residential) Alarm systems, telephone, sound, intercom, and public address systems. Separate from CR-11 electrical — do not accept one as a substitute for the other.
Sheet Metal / Ductwork CR-45 Fabrication and installation of sheet metal ductwork. Separate from CR-39 HVAC.
Boilers / Steam CR-74 Boilers, steamfitting, and process piping including solar systems.
Masonry CR-31 Block, brick, stone, and masonry systems.
Concrete CR-9 Concrete flatwork, foundations, and structural concrete.
Demolition / Wrecking CR-57 Wrecking and demolition of structures.
Painting CR-34 Painting and wall covering.
Glazing CR-65 Windows, glass, and curtain wall systems.
The ROC issues more than 80 specialty classifications. For trades not listed here — insulation (CR-40), landscaping (CR-21), asphalt paving (CR-13/69), floor covering (CR-8), and others — verify the specific code against the ROC's full classification list at roc.az.gov/license-classifications. Always confirm the code on the license certificate matches the actual work scope.

What GCs Are Responsible for Verifying

Arizona law is explicit: a GC cannot allow a sub to perform licensed trade work without the sub holding their own ROC license for that specific scope. This is not a soft obligation — it is a condition of your own license.

Your verification checklist

  • Verify the sub's ROC license number before contracting — not just before mobilization
  • Confirm the ROC record shows Active status, not Inactive, Expired, Suspended, or Revoked
  • Check that the license classification (the code: CR-11, CR-42, etc.) matches the actual work being subcontracted
  • Review the ROC record for any open complaints or Corrective Work Orders — unresolved CWOs are a significant red flag
  • Confirm the bond is active — if the bond lapses, the license automatically goes inactive between your checks
  • Re-verify before mobilization on longer projects, since license status can change after contracting
Pull a license status screenshot before signing and again before mobilization. If status changed between those two points, you have documentation that you exercised due diligence and caught the issue before work started. That documentation protects you with the ROC, your insurer, and the project owner.
TrackMyVendor monitors ROC license status for every Arizona sub in your roster and alerts you when a license expires or changes status. Start free — first 25 subs free →

Penalties for Hiring Unlicensed Subcontractors in Arizona

Arizona's enforcement approach is aggressive. The risks hit both the unlicensed sub and the GC who hired them:

Criminal liability — Class 1 misdemeanor

Unlicensed contracting is a Class 1 misdemeanor under A.R.S. § 32-1164 — the most serious class of misdemeanor in Arizona. Penalties include up to 6 months in jail and fines up to $2,500. The ROC can refer cases to the county attorney for criminal prosecution. A GC who knowingly allows unlicensed work may also face criminal exposure.

Statutory employer liability for workers' comp

Under A.R.S. § 23-902, if a GC hires an uninsured subcontractor and a worker is injured, the GC automatically becomes the "statutory employer" — absorbing 100% of the workers' compensation liability. Arizona mandates workers' comp for any employer with one or more employees. Verifying a sub's ROC license status (which requires active workers' comp) is the first line of defense.

ROC disciplinary action against your own license

Under A.R.S. § 32-1154, the ROC can suspend or revoke a GC's license for "aiding or abetting a licensed or unlicensed person to evade this chapter" or "allowing one's license to be used by a licensed or unlicensed person." A GC whose sub performed unlicensed work on their project is exposed to ROC disciplinary action even if the GC's own license is valid and current.

Insurance and lien complications

General liability policies typically limit or deny coverage for work performed by unlicensed subcontractors. Unlicensed contractors cannot enforce mechanic's liens in Arizona — complicating payment disputes and leaving work uncompensated. Project owners may pursue civil claims against the GC for defective work performed by unlicensed subs.


How to Look Up an Arizona ROC License

The Arizona ROC contractor search is the single authoritative source for all licensed Arizona contractors. It covers both commercial and residential licenses across all classifications.

1

Go to the ROC contractor search at azroc.my.site.com/AZRoc/s/contractor-search. You can search by contractor name, ROC license number, or zip code.

2

Confirm status is Active — not Inactive, Expired, Suspended, or Revoked. Also confirm the license classification code (e.g., CR-11, CR-42) matches the trade work being contracted.

3

Review complaints and Corrective Work Orders. The ROC record shows any open complaints or CWOs against the contractor. Multiple unresolved CWOs indicate enforcement problems worth investigating before contracting.

4

Verify the entity name matches your subcontract. The business name on the ROC record should match the entity you are contracting with. A license held by "ABC Electrical LLC" does not cover work performed by a sole proprietor named "ABC Electrical."

5

Log the result with a timestamp. Record the ROC number, classification, status, and date verified for each sub. TrackMyVendor stores this automatically and alerts you before the 2-year renewal deadline.

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Frequently Asked Questions

Does Arizona require a general contractor license?
Yes. Arizona requires all contractors — general and specialty — to hold an active ROC license. Commercial GCs hold a B-1 (unlimited) or B-2 (up to $2M) license; residential GCs hold a B license; dual commercial+residential contractors hold a KB-1 or KB-2. Unlicensed contracting is a Class 1 misdemeanor under A.R.S. § 32-1151.
Can a subcontractor work under my Arizona ROC license?
No. Arizona law explicitly prohibits license sublicensing. Every contractor performing licensed trade work must hold their own active ROC license for that specific scope. Allowing a sub to work under your license is grounds for the ROC to suspend or revoke your own license under A.R.S. § 32-1154.
What ROC license does a roofing contractor need in Arizona?
CR-42 (dual commercial and residential roofing), C-42 (commercial only), or R-42 (residential only). Verify the specific code matches the type of project. A residential-only R-42 license does not authorize commercial roofing work.
What happens if I hire an unlicensed contractor in Arizona?
Multiple risks: the unlicensed sub faces Class 1 misdemeanor charges. The GC faces potential ROC disciplinary action against their own license, statutory employer workers' comp liability if the sub's worker is injured, and general liability coverage disputes. The unlicensed sub also cannot enforce mechanic's liens, complicating payment resolution on the project.
How often do Arizona ROC licenses need to be renewed?
Arizona ROC licenses have a 2-year term. The ROC does not always send renewal reminders — it is the licensee's responsibility. An expired license is treated the same as no license for enforcement purposes. Electrical contractors (CR-11/C-11/R-11) must also complete 16 hours of continuing education per 2-year cycle.
Does a COI confirm that a sub is licensed in Arizona?
No. A COI confirms insurance coverage only — it says nothing about ROC license status. Verify ROC status through the Arizona ROC contractor search at azroc.my.site.com/AZRoc/s/contractor-search separately from your COI collection process.

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