How to Verify Roofing Subcontractors in California: The GC's Complete Checklist

Roofing subcontractors carry the highest fall fatality risk in construction—34% of all construction fall deaths involve roofs. They're also among the most common targets of workers' comp insurance fraud investigations. Before you sign that subcontract, this 7-point verification checklist helps you protect your project, your license, and your liability exposure.

Time required: 60+ minutes manually | Databases to check: 5+ | Target audience: General Contractors vetting roofing subs

This guide covers California C-39 roofing contractors. For general contractor verification, see our 5-step verification guide.

Why Roofing Subcontractor Verification Matters for GCs

As a General Contractor, your subcontractors' compliance is your liability. When a roofing sub causes problems, you're often the one holding the bag:

Vicarious liability: If their unlicensed or uninsured worker gets injured, you may be liable
Project delays: CSLB can stop work if they find an unlicensed sub on your job
OSHA citations: As the controlling contractor, fall protection violations can cite you too
Bond claims: If your sub abandons the job, their $25K bond may not cover your losses

Industry stat: Of the 1,200 fall fatalities between 2003-2013, 34% were from roofs. 90% of fatal falls involved no fall protection system. — OSHA Publication 3755

The California C-39 Roofing License: What GCs Need to Know

What a C-39 License Covers

Under CSLB Classification C-39, a roofing contractor installs products and repairs surfaces that seal, waterproof, and weatherproof structures. This includes:

Asphaltum, pitch, tar, felt, glass fabric
Urethane foam and spray-applied roofing
Metal roofing systems
Shakes, shingles, roof tile, slate
Any job over $500 (materials + labor)

Bond and Insurance Requirements

California roofing contractors must maintain:

$25,000 contractor bond — Required under B&P Code 7071.6 (increased from $15,000 on Jan 1, 2023)
Workers' Compensation Insurance — Under B&P Code 7125, C-39 contractors CANNOT be WC exempt. No exceptions.

Unlike some trades where sole owners with no employees can file for WC exemption, roofing is explicitly excluded due to high injury rates. Any C-39 contractor claiming WC exemption is either lying or operating illegally.

7-Point Roofing Subcontractor Verification Checklist

CSLB License Verification

Start with the California Contractors State License Board. This is your most important check—verify the license is Active with a C-39 classification.

What to verify:

Status: Must be "Active" (not Suspended, Revoked, or Expired)
Classification: Must include C-39 (Roofing)
Bond status: Active with current effective date
Workers' comp: Insurance on file (not exempt)
RME/RMO: Check who the Responsible Managing Employee is—are they actually involved in the business, or did someone "rent" their qualifier?
Complaint history: Review any disciplinary actions

Search CSLB License Database

Red flag: Recently reinstated after suspension, multiple complaints in past 3 years, or bond cancellation/reinstatement history.

Workers' Compensation Insurance

C-39 roofing contractors cannot be workers' comp exempt under California law. This is non-negotiable. If a roofer claims WC exemption, they're either operating illegally or misclassifying their license.

Verification steps:

Confirm WC insurance shows on CSLB record
Note the insurance carrier and policy expiration
Call the carrier directly to verify the policy is active
Request a Certificate of Insurance naming you as Certificate Holder

CSLB Workers' Comp Requirements

Red flag: WC "exempt" status on a C-39 license, expired coverage, or policy showing wrong class code. Roofing should be Class Code 5551—if you see 8810 (clerical) or another code, that's premium fraud and the policy won't cover a claim on your job.

General Liability Insurance Verification

Certificate of Insurance (COI) fraud is rampant in construction. Don't just accept a certificate—verify it's real.

How to verify it's not fake:

Request your company be added as Additional Insured
Call the carrier directly—find the number independently, not from the certificate
Verify the policy number, effective dates, and coverage limits
Check that coverage limits meet your project requirements
Request the carrier email confirmation directly to you

Creating a fake COI is a felony. But it happens frequently enough that insurance industry groups have published guides on spotting fake certificates.

Federal Debarment Check (SAM.gov)

The System for Award Management (SAM.gov) maintains the federal Excluded Parties List. Debarred contractors cannot work on federal projects, and debarment indicates serious compliance issues like fraud, tax evasion, or criminal conduct.

How to search:

Go to SAM.gov (no login required for exclusion searches)
Search by business name
Also search by owner/principal names
Check both exact and partial matches
Search any DBA (doing business as) names

Search SAM.gov Exclusions

Red flag: Any active exclusion. Even an expired exclusion warrants careful review—understand why they were debarred before proceeding.

OSHA Safety Record

Roofing has the highest fall fatality rate in construction. OSHA tracks workplace safety inspections, violations, and penalties. A contractor with repeat safety citations may have a poor safety culture that puts your project at risk.

What to look for:

Fall protection violations (1926.501): The most common roofing citation
Serious violations: Could result in death or serious injury
Willful violations: Intentional disregard—penalties up to $161,000+ (adjusted annually)
Repeat violations: Same violation found multiple times
High penalty amounts: Indicates severity

Search OSHA Establishment Records

Small contractors doing only residential work may not have OSHA records. Absence of records doesn't necessarily indicate a problem—but for commercial roofing subs, you should expect to find inspection history.

Business Standing Verification

Verify the contractor is a legitimate, registered business entity in good standing with the state.

What to verify:

Secretary of State status: Active, not suspended or dissolved
Entity type: LLC, Corp, Sole Prop—matches what they told you
Business address: Verify it's a real location, not a virtual mailbox
Years in business: Does formation date match their claims?

CA Secretary of State Business Search

References, Payment History, and Crews

Database checks verify compliance. References verify competence. But you also need to verify they pay their bills and actually have crews—not just a license and a phone.

What to ask references (GCs they've worked for):

Did they complete the project on time and within budget?
How did they handle change orders and unforeseen issues?
Were there warranty claims after completion?
How was their safety performance on site?
Would you hire them again?

Payment verification (ask for trade references):

Request unconditional lien waivers from their recent projects—if they don't pay suppliers, you get the lien on YOUR project
Ask for their primary material supplier as a reference (roofing supply house)—are they current on their account?

Crews vs. labor brokers:

Do they have their own W-2 crews, or do they sub out the labor? Some "roofing companies" are really just brokers.
If they use subbed labor, who carries WC for those workers?

Request 3 GC references for similar projects completed in the last 2 years, plus at least one trade reference (supplier). Be wary if they can only provide older references or residential work when bidding commercial.

Red Flags When Vetting Roofing Subcontractors

License Red Flags

×Recently reinstated after suspension
×Multiple complaints in past 3 years
×Bond cancellations or lapses
×License classification doesn't include C-39
×License expiring before project completion
×RME/qualifier works for multiple companies

Insurance Red Flags

×Claims WC exemption (illegal for C-39)
×WC policy shows wrong class code (not 5551)
×Carrier can't verify the COI
×Reluctant to add you as Additional Insured
×"My guys are all 1099s" (worker misclassification)
×Coverage limits below project requirements

Safety Red Flags

×OSHA fall protection citations
×Willful or repeat violations
×High Experience Modification Rate (EMR > 1.0)
×No documented safety program
×Can't provide OSHA 300 logs when asked

Business Red Flags

×Business name doesn't match license
×Recently formed entity with "20 years experience"
×No physical yard/office you can visit
×Can't provide trade references (suppliers)
×Bid significantly below other subs
×Pressure to skip vetting ("do you want the job done or not?")

California Roofing-Specific Compliance Requirements

Cool Roof Requirements (Title 24)

California's Title 24 energy code requires cool roofs for many building types. Verify your roofing sub understands current requirements and has experience with compliant materials and installations.

Fire-Rated Roofing (WUI Zones)

Projects in Wildland-Urban Interface zones require Class A fire-rated roof assemblies. Verify the sub has experience with fire-rated installations and can provide proper documentation.

Manufacturer Certifications

Extended manufacturer warranties (GAF, CertainTeed, Owens Corning) often require certified installers. If the project spec calls for manufacturer warranty, verify the sub holds current certification. Red flag: Can't produce certification documents when claiming they can provide manufacturer warranty.

What Happens If You Hire an Unverified Roofing Sub

Skipping verification exposes you to significant legal and financial risk:

GC civil liability: Under B&P Code 7031, you may be considered the responsible party for an unlicensed sub's work
No mechanics lien protection: Unlicensed contractors cannot file liens, but you still owe material suppliers
Insurance coverage gaps: Your GL policy may exclude claims arising from unlicensed sub work
OSHA citations flow to GC: As controlling contractor, their fall protection failures can cite you
Lien exposure: If your sub doesn't pay their suppliers, those suppliers can lien your project

Note: The criminal penalties ($15,000 fine, 6 months jail) apply to the unlicensed contractor, not the GC who hires them. Your exposure as a GC is primarily civil—but that civil exposure can be substantial.

Ongoing Verification: How Often to Re-Check

Verification isn't one-and-done. Licenses expire, insurance lapses, and new violations occur. Industry best practice:

Annual: Full re-verification of license, bond, insurance for all active subs in your vendor list
Before each project: Quick license status and insurance expiration check
After any incident: Re-verify if there's a workplace injury, complaint, or project issue
On news of violations: If you hear about OSHA citations or legal issues, verify immediately

Frequently Asked Questions

What license does a roofing contractor need in California?

California roofing contractors need a C-39 Roofing license from the CSLB. Any roofing job over $500 (materials and labor) requires this license. The C-39 classification covers asphalt, tile, metal, shingles, foam, slate, and other roofing materials.

Can roofing contractors in California be workers comp exempt?

No. Under California Business & Professions Code Section 7125, all contractors with a C-39 Roofing classification are required to have Workers' Compensation Insurance. Unlike some other trades, roofing contractors cannot file for a workers comp exemption due to the high-risk nature of roofing work.

How much is a California roofing contractor bond?

California requires a $25,000 contractor bond for all licensed contractors, including roofers. This amount increased from $15,000 on January 1, 2023 under Senate Bill 607. The bond protects consumers against financial loss from incomplete or defective work.

How do I verify a roofing contractor insurance certificate isn't fake?

Call the insurance carrier directly using a phone number you find independently—never use the number printed on the certificate. Verify the policy number, effective dates, and that your company is listed as Additional Insured. Request the carrier send confirmation directly to you.

What happens if I hire an unlicensed roofing contractor in California?

Hiring an unlicensed contractor exposes you to significant civil liability. Under B&P Code 7031, unlicensed contractors cannot legally sue to collect payment. You may be liable for worker injuries, have no bond protection, and the work may not meet code. Note: The criminal penalties ($15,000 fine, 6 months jail) apply to the unlicensed party, not the GC—but your civil exposure can be substantial.

Skip the Manual Database Searches

This 7-point checklist takes 60+ minutes per subcontractor when done manually. SiteVetter aggregates CSLB, SAM.gov, OSHA, DOL, and EPA data in seconds—including violations you'd miss searching databases you don't know exist.

What manual searches miss: DOL wage violations, EPA environmental citations, debarment records under DBA names, OSHA violations at previous business names. SiteVetter checks them all.

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