Two licences, similar names, very different legal effect. Confusion between them costs Queensland building businesses real money, and the conversation usually happens too late, in Brisbane and Ipswich and up and down the Gold Coast, when a company discovers the person it counted on cannot fill the role it needs filled.
A QBCC site supervisor licence and a nominee supervisor licence both authorise someone to oversee building work. That is where the similarity ends. They sit at different points in a company’s licensing structure, they carry different responsibilities, and one of them cannot substitute for the other no matter how experienced the holder is.
This article sets out what each licence authorises, what neither authorises, why the distinction matters commercially, and how to work out which one your business actually needs.
Start with what a contractor licence does
Both supervisor licences make more sense once you understand the licence they sit beneath.
A contractor licence is the one that authorises entering into building contracts. An individual can hold one in their own name, or a company can hold one in the company’s name. The contractor is the party that signs with the client, invoices, carries the commercial risk and holds the financial obligations, including minimum financial requirements and annual reporting.
Neither supervisor licence does any of that. This is the single most important thing to understand about both: a supervisor licence is about overseeing work, never about contracting for it.
What a nominee supervisor licence does
A nominee supervisor licence is issued to an appropriately qualified director, secretary or employee of a company who is nominated to oversee the scope of building work the company is contracted to undertake.
A company cannot hold qualifications or accumulate site experience, because a company is a legal construct rather than a person. It satisfies the technical competence requirement through its nominee. The nominee must meet the experience, technical skills and managerial qualification requirements for the same licence class as the company’s contractor licence. A company holding a Low Rise builder contractor licence needs a nominee qualified at Low Rise.
The nominee is responsible for ensuring the work the company carries out meets the relevant Australian Standards and the National Construction Code. That responsibility is personal. It attaches to the individual holding the nominee licence, not to the company that employs them.
What a nominee cannot do is contract. A nominee supervisor cannot enter into building contracts directly with the public, a builder or a principal contractor. That is done through the company entity holding the contractor licence. The nominee is the responsible technical person inside the company, not a party to the company’s contracts.
What a QBCC site supervisor licence does
A QBCC site supervisor licence authorises the holder to supervise building work on site, on behalf of a licensed contractor. It is an employee-level licence. The holder works for a licensed builder and oversees the day-to-day running of construction sites, coordinating trades and ensuring work is carried out correctly.
A QBCC site supervisor licence comes in the same classes as the contractor and nominee licences, so a site supervisor may be licensed at Low Rise, Medium Rise or Open depending on their qualifications and experience.
Like the nominee licence, a QBCC site supervisor licence carries no contracting power. The holder cannot enter into contracts with clients, cannot run their own building business under it, and carries no financial responsibility for the licensed entity.
The distinction from a nominee is narrower but decisive: a site supervisor supervises work on site, while a nominee carries the company’s technical compliance responsibility for the entire scope of building work the company undertakes. One is an operational role; the other is a structural licensing position.
Where section 43 brings them together
The two licences intersect in the supervision requirement that applies to all licensed building work.
A licensed contractor, whether an individual or a company, must ensure building work is properly supervised. That supervision can be provided by the contractor personally, by the company’s nominee, or by an officer or employee holding an appropriate licence of the relevant class, which includes a nominee supervisor licence, a QBCC site supervisor licence, an occupational licence or a contractor licence of the relevant class.
This is why a company running multiple sites employs site supervisors. The nominee cannot be everywhere, and the legislation does not require them to be. Supervision means ensuring work is regularly checked and compliant with the Building Code of Australia, relevant Australian Standards and the contract requirements. It is genuine oversight and reasonable availability rather than a requirement to stand on every site continuously.
So site supervisors extend a company’s supervisory capacity across its projects. What they do not do is replace the nominee position. A company still needs a nominee attached to its contractor licence regardless of how many site supervisors it employs.
The mistake that costs money
Here is the scenario that brings companies to this question, and it is common enough to be predictable.
A building company’s nominee resigns, retires or has their own licence affected. The company has a capable site supervisor who has been running its projects for years and knows the business inside out. The obvious answer seems to be to move that person into the nominee role.
It is often not that simple. A QBCC site supervisor licence does not automatically qualify the holder to act as a nominee supervisor. The nominee must independently meet the experience, technical skills and managerial qualification requirements for the class matching the company’s contractor licence. A site supervisor may satisfy some of these and not others, and the gap is frequently the managerial qualification or the documented breadth of project experience rather than the practical capability.
Meanwhile the company cannot lawfully contract without a nominee attached to its licence. There is a notification obligation when a nominee departs, and a business that assumed the transition would be straightforward finds itself unable to sign new work while it sorts the licensing out.
The reverse mistake is less costly but still wasteful. A tradesperson intending to start their own building business applies for a site supervisor licence, on the reasonable assumption that a supervision licence is a step toward running jobs. It authorises supervision under someone else’s contractor licence. It does not authorise contracting, and it is not a prerequisite for the contractor licence they actually need.
Working out which one you need
The question resolves quickly once you frame it around what the person will actually do.
If they will sign contracts with clients and carry commercial responsibility, they need a contractor licence, individually or through a licensed company. Neither supervisor licence gets them there.
If they are the qualified person who will carry a company’s technical compliance responsibility so the company can hold a contractor licence, that is the nominee supervisor position. The company cannot trade lawfully without it.
If they will run sites day to day, under a company that already has its contractor licence and nominee in place, a QBCC site supervisor licence is the right fit.
And if you are a company owner asking which of these your business needs, the honest answer is usually more than one. You need the contractor licence for the entity, a nominee attached to it, and site supervisors sufficient to supervise the work you have on. They are complementary rather than alternatives.
Structural risk worth planning for
There is a strategic point buried in this that established builders should take seriously.
A company whose only qualified individual is its nominee has a single point of failure written into its licence. If that person leaves, the company’s authority to contract is immediately exposed, and the pool of people who can step in is limited to those who independently meet the nominee requirements for the relevant class.
Companies that develop qualified people internally, including site supervisors working toward nominee-level qualifications, have more resilience than companies that do not. That is a succession question as much as a licensing one, and it is considerably cheaper to address before the nominee gives notice than after.
Where this sits against the rest of your licensing
Getting the supervisor licences right does not resolve the other requirements. The company still has to satisfy the financial requirements, meet its annual reporting obligations and hold the correct licence class for the work it takes on.
For a sole trader looking at the builder licence pathway for trades QLD, the relevant question is usually the contractor licence rather than either supervisor licence. For an established company needing to replace a QBCC nominee supervisor, the distinction covered here is exactly the issue. For a developer builder licence QLD application, the nominee position is typically the mechanism by which the development entity gains head-contractor capability.
Get the licence type right the first time
A QBCC site supervisor licence and a nominee supervisor licence are both legitimate, both useful, and not interchangeable. Applying for the wrong one costs application fees and months, and discovering the difference during a nominee transition costs considerably more.
Builders Helping Builders works with existing licence holders across Southeast Queensland, including Brisbane, the Gold Coast, the Sunshine Coast, Logan, Ipswich and Toowoomba. We have run building businesses ourselves, so we look at these questions through what the business needs to keep trading rather than as a form-filling exercise.
If you are unsure which licence type fits your situation, or you are facing a nominee transition and want to know whether your site supervisor can step up, book a licensing readiness check at bhba.com.au. We will work through what each person in your business is qualified for and what the company needs to stay contracting.
General disclaimer
This article is intended for general information purposes only and should not be relied upon as legal, financial, or licensing advice. Licensing requirements change, and every builder’s circumstances are different. Readers should confirm current requirements with the QBCC and seek advice from appropriately qualified construction accountants and legal professionals regarding their individual or company situation.
