SIA offences: the real cost of supplying unlicensed staff

The Approved Contractor Scheme is voluntary. The licensing regime underneath it is not, and it carries a maximum sentence of five years. The gap between those two facts is where most compliance effort in UK guarding is misdirected.

In short: Under the Private Security Industry Act 2001, supplying an unlicensed operative is an either-way offence with a five-year maximum. Directors can be prosecuted personally for consent, connivance or neglect. Failing to check a licence is not a defence, which makes the verification record the thing that actually protects a business.

The four offences that appear in prosecutions

The Private Security Industry Act 2001 created the SIA and the compulsory licensing of individuals carrying out designated activities. Four provisions do most of the work in enforcement.

Section 3 covers engaging in licensable conduct without a licence, and it applies to the individual. Section 5 covers the supply of unlicensed operatives, and it applies to the business. Section 19 covers obstructing SIA officials or failing to respond to a request for information. Section 23 is the one that reaches individuals at the top: consent, connivance or neglect on the part of directors in relation to employing unlicensed guards.

The asymmetry between the first two is the point of this article. Working without a licence, under section 3, carries up to six months and a fine. Supplying an unlicensed operative, under section 5, is an either-way offence with a maximum of five years' imprisonment and an unlimited fine. The heavier exposure sits with the company that deploys, not the person deployed.

Alongside these, the SIA identifies further offences including breaching licence conditions, making false statements, and falsely claiming Approved Contractor Scheme status.

What the sentences actually look like

Here the headline number and the practical outcome diverge sharply, and it is worth being straight about it rather than trading on the five-year figure.

Reported magistrates' court outcomes for section 5 matters tend to be modest financial penalties rather than custody. Fines in the low hundreds to low thousands, plus costs and a victim surcharge, are typical. A director prosecuted for supplying a single unlicensed door supervisor might face a total in the region of a thousand pounds once costs are added.

So if the calculation were purely financial, the deterrent would be weak. That reading misses where the damage lands. A section 5 conviction is a criminal conviction against the business and often against a named director. It has to be disclosed. It sits badly against Approved Contractor Scheme status and against the pre-qualification questionnaires that public sector and large corporate buyers use. In a sector where the tender is often won on assurance rather than price, the fine is the least expensive part of the outcome.

Enforcement also has a range of options short of prosecution: written warnings, improvement notices for businesses, suspension or revocation of licences, and in appropriate cases asset confiscation where a crime has taken place. SIA investigators can enter premises and request information in connection with an investigation.

Two findings that catch businesses out

Two recurring themes run through reported prosecutions, and both are avoidable.

The first is that failing to check is not a defence. SIA investigators have been explicit that directors who do not carry out proper checks on the operatives they are responsible for will be pursued. Cases have involved an unlicensed operative deployed over a period of months without anyone verifying licence status. The absence of a check is not treated as an innocent oversight; it is the neglect that section 23 describes.

The second is that non-front-line directors still need licences. The SIA's position is that all directors of companies supplying officers who undertake licensable activity must hold an SIA licence, whether or not they personally work front line. A company has been found supplying door supervisors while its sole director held no licence, resulting in a section 3 conviction against that director.

Neither finding requires bad faith. Both are administrative failures that become criminal matters because the statute attaches liability to the deployment decision rather than to intent.

Enforcement is active, and reform does not pause it

This is not a dormant regime. A co-ordinated national inspection day on 21 June 2026 saw more than forty officers from the SIA's Inspections and Enforcement Directorate, supported by policing partners, visit 224 licensed premises and carry out 450 licence checks, identifying six suspected section 3 offences.

Read those numbers as an operator rather than as a statistic. Four hundred and fifty checks in a single day means the realistic exposure is not an investigation triggered by a complaint; it is an officer being checked on an ordinary shift at an ordinary venue.

There is also a reform question in the background. The Government has announced a phased transition to a new regulatory regime, but that will take time to put in place. Until it does, the current law applies and enforcement continues. Waiting for the new framework before tightening licence verification is a decision to carry the existing risk for the whole transition period.

Three checks worth running this week

None costs anything, and all three are things an investigator could ask about.

1. Confirm every director who needs a licence holds one. If your company supplies officers carrying out licensable activity, that includes directors who never work front line. This is a single afternoon's work and removes an entire category of exposure.
2. Check whether your licence verification leaves a record. Not whether checks happen, but whether you could show when a specific operative's licence was last verified. Since failing to check is not a defence, the evidence of checking is the defence.
3. Test one deployment backwards. Pick a site and a shift from last month and establish who worked it and what their licence status was on that date. If that takes longer than a few minutes, the same question from an investigator will be considerably less comfortable.

Linking the licence to the deployment

The third check is the one that usually exposes the gap, because two separate systems have to agree. Licence data tends to live in HR records or a spreadsheet. Deployment lives in a roster. Neither on its own answers "was this person licensed on the night they worked that site", which is precisely the question a section 5 investigation asks.

Bringing the two together is what closes it. In COREDINATE, each officer's qualifications and certificates are held against their profile, and every checkpoint scan is written to the digital daily occurrence book with a tamper-proof timestamp and the officer's identity. That produces the deployment side of the answer as a by-product of the work rather than as a separate reporting task, and reports turn it into a document you can hand over.

For the voluntary side of the regime, and how buyers read it in procurement, our guide to the SIA Approved Contractor Scheme covers the assessment process in full. The scheme sits on top of the licensing duties described here; it does not substitute for them.

Frequently asked questions

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