Main Contractor vs Subcontractor — Who Is Responsible for CPD Submission?

The main contractor owns CPD submission. Subcontractors do not need their own BAS. Here is exactly what each party is responsible for on site.

Short Answer

The main contractor is responsible for Construction Productivity Data (CPD) submission — covering all workers who enter the site, regardless of which subcontractor employs them.

Subcontractors do not need their own Biometric Authentication System (BAS) and do not submit CPD separately. Their workers register and check in through the main contractor's system. The main contractor carries the compliance obligation for the accuracy and completeness of that data.

What is the main contractor responsible for?

Under BCA's automated CPD submission framework, the builder — the main contractor — is accountable for the following:

• Operating an integrated BAS on site that captures check-in and check-out for all workers
• Ensuring all workers — including those employed by subcontractors — are registered on the BAS before they commence work on site
• Maintaining accurate trade data for every registered worker
• Submitting CPD data to BCA via SGBuildex each month
• Ensuring submissions are complete and accurate before applying for as-built Buildability and Constructability clearance

This means the main contractor carries compliance risk for data it does not entirely control — worker check-in behaviour, subcontractor registration accuracy, and trade assignments are all inputs that depend on coordination across multiple parties.

What are subcontractors responsible for?

Subcontractors do not submit CPD and do not need their own BAS. Their operational responsibilities are:

• Registering all their workers on the main contractor's BAS before work commences
• Ensuring workers carry valid work passes on site
• Ensuring workers check in and out through the site biometric system on every visit
• Informing the main contractor of any trade changes, new workers, or workers leaving the project

Missing check-ins, unregistered workers, or outdated trade assignments create data gaps that flow directly into the CPD submission — and the main contractor is the one accountable for those gaps at clearance stage.

The practical risk for main contractors

You are submitting data you do not fully control. A subcontractor whose workers consistently forget to clock out, or who adds workers to site without registering them first, creates CPD inaccuracies that your team has to catch and correct before submission.

This is why review capability before each submission cycle matters — not just automation. Being able to see incomplete records, flag missing check-outs, and correct trade data before it goes to BCA is as important as the API connection itself.

Responsibility breakdown by party

What about workers on multiple sites?

A subcontractor's workers often move between multiple active sites, each managed by a different main contractor. In most BAS setups, workers need to be registered separately under each main contractor's system for each project — there is no shared registry between main contractors.

How Hubble handles this differently

Hubble's centralised resource management system allows main contractors to reuse subcontractor and worker data across multiple projects — eliminating repeated registration for the same workers. 

It also allows subcontractors to assign their workers across multiple main contractors' projects without starting from scratch each time. This is particularly useful for subcontractors who run concurrent crews across several active sites.

What this means in practice for main contractors

The accountability structure puts the main contractor in the position of managing compliance for data produced by parties they do not directly control. Before your first SGBuildex submission goes live, three things need to be in order across every subcontractor on site:

• Registration — every worker from every subcontractor must be in your BAS before they arrive on site, not after
• Trade accuracy — each worker tagged to the correct trade in BCA's new 30-category list, with a process for updating trades when deployment shifts mid-project
• Check-in discipline — workers from all parties checking in and out consistently, with auto-checkout rules in place to handle the inevitable missed clock-outs

Getting subcontractors aligned on these three points —before the first submission cycle — is the operational work that matters most. The API connection handles the submission. The data quality is a people and process problem.

Managing multiple subcontractors across active sites?

Talk to us about how Hubble's centralised resource management handles worker registration across projects and main contractors.

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Related

• Automated CPD Submission from 1 May 2026 — Does It Apply to Your Project?
• What Happens When CPD Data Is Wrong — Amending and Resubmitting via SGBuildex
• Hubble SGBuildex CPD Module — How It Works