CSCS Statement: CISRS

Updated 01/10/2026 – All quotes within this statement should be attributed to Sean Kearns, CSCS Group Chief Executive.

CSCS can confirm that it has received formal notice from CISRS to terminate its licence to use the CSCS Mark on CISRS cards, with a proposed termination date of 31 May 2027.

The notice was unexpected, particularly as CSCS had been awaiting an update from CISRS on progress against outstanding obligations under its existing licence. We are now following the established contractual and licensing process to ensure that any withdrawal and subsequent transition in carding arrangements is managed properly.

Sean Kearns, CSCS Group Chief Executive, said: “We are disappointed that CISRS chose to communicate its proposed withdrawal publicly before a transition plan had been discussed with and approved by CSCS, and before the implications for cardholders, employers and the wider industry had been fully considered.”

CSCS understand that a key concern for CISRS relates to Clause 4 of the Construction Leadership Council’s requirements and its view that this creates a conflict with the CISRS licence agreement.

“CSCS does not share that interpretation and, importantly, neither do a number of key organisations across the industry.”

“We have sought clarification from the Construction Leadership Council, employers, trade unions and scaffolding contractors. The consistent assurance we have received is that Clause 4 does not prevent CISRS from continuing to operate under its existing CSCS licence, nor does it change the industry’s expectation that appropriately qualified workers undertaking scaffolding activities in construction should hold CSCS-logoed cards.”

This position has also been reinforced by Build UK. In a letter to NASC, Build UK’s Chair has confirmed that there is no intention to prevent scaffolding occupations from working in sectors outside construction and that Build UK will continue to support the CLC recommendation following clarification of the intent behind Clause 4. Unite the Union has also reaffirmed its support for the recommendation.

“Scaffolding is an occupation undertaken extensively within construction. The fact that scaffolding skills are also required in other sectors does not mean that scaffolders working in construction should no longer have access to a CSCS-logoed card.”

Other CSCS Alliance schemes successfully accommodate occupations that operate across several industries by providing CSCS-logoed cards for construction and, where appropriate, alternative non-logoed cards for work outside construction.

We therefore do not believe Clause 4 prevents CISRS from continuing within the existing licensing arrangements.

“It is also important to recognise that the underlying principle is not new. Equivalent wording relating to non-construction occupations has featured in CLC requirements published in 2017, 2020 and 2024. CISRS has operated as a CSCS Alliance scheme throughout that period and had not previously identified this as creating a conflict with its licence – we can’t see what has changed since 2017, CISRS need to explain.”

CISRS has advised CSCS that it has taken legal advice which reaches a different conclusion. However, that advice has not yet been provided to CSCS. Without understanding the basis of that interpretation, it is difficult for us to assess the issue properly or explore whether any practical solution is required.

“If there is a genuine conflict, we want to understand it. CSCS remains willing to work constructively with CISRS to examine the issue and, where necessary, identify a solution. No one wants to be in this position, particularly given the potential consequences for cardholders, employers and the wider scaffolding sector.”

CSCS’s immediate priority is to support the thousands of existing cardholders, apprentices, employers, training providers and others who rely on established carding arrangements. Any transition must therefore be controlled, orderly and properly communicated.

“It would be premature to speculate about future arrangements until CISRS has provided its proposed withdrawal and transition plan. Wider communications to industry will follow once that has been received and considered by CSCS in its capacity as Licensor.”

“Whatever future carding arrangements emerge, employers and contractors will continue to have responsibilities under the Construction (Design and Management) Regulations and other applicable requirements to ensure that people working on construction sites are appropriately trained, qualified and competent.”