Running CPD for a building business with several licence holders

A company licence does not do CPD. The individuals behind it do. If your business operates through a company or partnership licence and relies on several people who each hold a contractor licence or a qualified supervisor certificate, then you are not running one CPD obligation. You are running one for every licence holder on the books, each with their own renewal date, their own points tally and their own evidence trail.

That is an administrative problem before it is a training problem. The learning itself is straightforward: the approved topic areas are wide, the points are earned at a known rate, and there is plenty of material available. What catches building businesses out is the record keeping around the learning — knowing who is due, when they are due, where their evidence is, and what happens to all of it when someone resigns.

This article is about that system. It assumes you already understand the obligation itself; if you need the mechanics first, the PointCPD guide to how NSW builder CPD works sets out the points, the topic areas and the audit process. What follows is how to run it across a team.

Why the company licence changes nothing

The requirement applies to individuals licensed as a builder or swimming pool builder under the Home Building Act 1989. That means contractor licence holders and qualified supervisor certificate holders. A company or partnership licence does not itself earn points, and it cannot hold them on someone’s behalf.

The practical consequence is that the obligation does not transfer. If your business holds the company licence and three people hold the individual licences that let the work proceed, there are three separate obligations. Each of those people needs twelve CPD points per year, earned in the twelve months before their own renewal. Renewal or restoration of the licence is refused if the requirement is not met — and it is refused for that individual, which means the business loses the qualified supervisor it was relying on for that class of work.

This is why the register matters more than the training calendar. A training calendar tells you what learning is available. A register tells you which licence is exposed, on what date, and who is responsible for closing the gap.

Build a register of licence holders, not a list of staff

The register is the core document. It should list every individual in the business who holds a contractor licence or a qualified supervisor certificate, and for each one it needs their licence number, their licence class, and their renewal date. Those last two fields are what the whole system runs on.

Two details are easy to get wrong. First, the register should be organised by individual, not by role. If someone changes roles internally but keeps their licence, their obligation does not change. Second, the register should include people who are not on the tools. A director who holds a contractor licence and signs contracts occasionally is still a licence holder with a renewal date.

It also helps to record, against each person, the date their current CPD period began. Because points are earned in the twelve months before renewal, the period is not the calendar year and it is not the financial year. It is a rolling window tied to the renewal date, and it moves every time the licence is renewed.

One more field is worth the trouble: a note of surplus points carried forward. Up to eleven surplus points carry forward for twelve months, and anything beyond that is forfeited. If a supervisor does a heavy year of learning, the surplus is an asset for the next period — but only if someone has written it down.

Decide who owns the reminder, and make it a person

Every CPD failure in a multi-licence business traces back to the same cause: nobody owned the reminder. The obligation sits with the individual licence holder, which is legally correct, but in a business of any size the individual is busy running jobs and will not track their own renewal window reliably. Someone in the office has to.

Make it one named person. Not a department, not “the office”, not a shared inbox. One person who holds the register, works backwards from each renewal date, and starts the conversation early enough that the learning can be scheduled around the programme. If two people share it, both will assume the other is watching, and the person whose licence is closest to expiry will not find out until it is tight.

The owner’s job is not to do the learning. It is to answer four questions for every licence holder, every period: how many points are banked, how many are still needed, what is booked, and where is the evidence. If the owner cannot answer all four for every person on the register, the system is not working.

The reminder cycle should start well before the renewal window, because the point of the system is to avoid a scramble. A supervisor who needs to complete a block of learning should be told while there is still room in the programme to send them. A reminder that arrives in the week before renewal is not a reminder; it is a problem.

Collect evidence centrally, at the point it is issued

Compliance is self-recorded. The licence holder keeps a diary and supporting evidence, and nothing is submitted to the regulator unless that person is audited by Building Commission NSW, which runs both regular and random audits. Records must be retained for three renewal periods.

That combination — self-recorded, no submission, retained for years — is what makes central collection the right model. If each licence holder keeps their own paperwork in their own ute, the business has no way to confirm that the evidence exists until the day it is needed. An audit request that arrives while a supervisor is on leave, or after they have left, becomes a genuine problem.

The central folder should hold, for each attendance, the provider-issued record. A proper record of attendance identifies the participant and their licence number, the course or event title and its CPD topic area, the course code, the date, time and location, the duration, the assessment type, the trainer’s name and organisation, and the points earned. If a record is missing any of those, ask the provider for a corrected one while the course is still recent.

The folder should also hold a running tally for the current period and a note of any points carried forward. That tally is what lets the owner answer the four questions above without reading every certificate.

Route the learning through the approved topic areas

The eight approved topic areas are technical issues, sustainability, compliance, communication, dispute resolution, contracts, safety and business management. That spread is wide enough that most of the learning a supervisor would do anyway can be pointed at a topic area, which makes the system easier to run: you are not inventing development activity, you are recording it against the right heading.

Two rates are worth knowing when you are planning a period. Interactive learning on an approved topic with identifiable learning outcomes, delivered by a provider with industry expertise, online or face to face, earns one point per hour. Learning with an assessable outcome tied to a National Training Package or a university qualification, delivered by a registered training organisation or an Australian university, earns two points per hour. A short course with an assessment is therefore a more efficient use of a supervisor’s time than the same number of hours of attendance-only learning.

There is also a category that businesses routinely forget. Employing an apprentice or trainee, or having a partner or associate learn on the business’s behalf, earns one to two points, capped at four points a year combined. If you run apprentices, that is a real contribution to someone’s total — but it has to be recorded like any other activity, and it has to be shared between the licence holders who are claiming it.

When you choose providers, remember that NSW describes the activities that count, not the providers that deliver them. Building Commission NSW and NSW Fair Trading are government bodies; neither approves or accredits CPD providers. The test is whether the activity meets the description, and whether the record of attendance gives you everything the folder needs. The PointCPD course catalogue is one place to look, but the same test applies to any provider.

What happens when a supervisor leaves

This is where most multi-licence systems fail, and it fails quietly. When a supervisor resigns, three things happen at once, and only one of them is usually handled.

The first is the practical one: the business loses a qualified supervisor, and may need to replace them to keep certain work proceeding. The second is the record: their CPD evidence, tallies and carry-forward notes still belong in the business’s records, because records must be retained for three renewal periods. The third is the obligation itself: CPD attaches to the individual, so the departing supervisor keeps their own obligation and their own renewal date. The business does not inherit it, and cannot complete it on their behalf.

The mistake is letting the departing person take the folder with them. Once they have left, retrieving a record of attendance from a former employee is awkward at best. The handover should be part of the exit process: before the final pay is processed, the CPD folder for that person is copied into the central record and marked as closed, with the date they left. That record is what the business holds if it is ever asked to demonstrate how the obligation was managed while the person was employed.

The replacement then enters the register as a new line, with their own licence number, class and renewal date. If they arrive mid-period, their CPD period is already running — it does not restart because they changed employer. That is worth establishing in the first week, because a new supervisor who arrives close to their renewal date is an immediate scheduling problem, not a future one.

A worked example

A builder in western Sydney operates through a company licence and has four individuals on the register: two directors who hold contractor licences, and two qualified supervisors who carry the site work. The office manager holds the register and sends reminders.

One of the supervisors resigns in the middle of the year to move interstate. His folder is copied to the central record on his last day and closed out. Three months later, one of the directors is due to renew. The office manager checks the register, finds the director is short of the required points for the period, and books a short assessed course that earns at the higher rate, with enough time before the renewal date for the record of attendance to be issued and filed. The renewal proceeds.

The replacement supervisor starts two months later. On his first week, the office manager records his licence number and renewal date, and discovers his renewal is close. He has been earning points with his previous employer, but the evidence is with them. The office manager requests a copy of the records, files them centrally, and books the remaining learning needed for the period. The lesson in the example is not the course booking. It is that the register told the business where the exposure was, in both cases, while there was still time to act.

Retention, audits and the exemption question

Records must be retained for three renewal periods, so the central folder needs a retention rule as well as a filing rule. Practically, that means an annual review in which folders for people who have left, or periods that have rolled out of the retention window, are archived rather than deleted. If a former supervisor is audited for a period during which they worked for you, the evidence you hold is the evidence that answers the audit.

Exemptions are narrow. They are available only for serious illness or misadventure, and are requested on a Request for Exemption form at renewal. They are not a mechanism for a busy year, and they are not something a business can apply for on its own account. If a licence holder genuinely cannot meet the requirement for one of those reasons, the request is made at renewal — so the register should flag it at the same time it flags the shortfall.

For the full sequence from register check to filed record, the NSW builder CPD renewal checklist walks through the steps. The two related articles on how the CPD obligation sits with a company licence and on record retention for NSW builders cover the legal background in more detail.

The system in one page

If you want to reduce all of this to something you can audit yourself, it comes down to a short list. Every licence holder is on the register with a licence number and a renewal date. One named person owns the register and the reminder cycle. Evidence is filed centrally in the week it is issued, not at renewal. Surplus points are written down so they are not forfeited. Departing supervisors have their folders closed out before they leave. And the whole thing is reviewed once a year, against the retention requirement, so that nothing is quietly deleted.

None of that requires new software. A spreadsheet and a shared folder will do it, provided the ownership is real and the filing happens when the record arrives. What it does require is the recognition that CPD in a multi-licence business is a compliance system, not a personal responsibility. The licences belong to individuals, but the risk of losing them belongs to the business.

Questions builders ask

• Business
• CPD
• Licensing
• Record Keeping

Published 12 July 2026. General information for builders, not legal, financial or engineering advice for a specific job. Check current requirements with the relevant regulator or standard before relying on them.