Municipalities, regions and public authorities are responsible for ensuring that suppliers awarded public contracts are legitimate – and that the conditions are met in every subcontractor tier. Checks are needed both in the procurement and continuously during the contract period.
The requirements come from several directions: the exclusion grounds in the Public Procurement Act (LOU), labor law conditions at collective agreement level, tax checks, staff register requirements in certain industries – and, for critical operations, the CER Directive's requirement to background-check supplier staff as well.
In practice, the failures usually appear after the award: in the question of who actually performs the work, under which identity and with what right to work.
The process must include the following
The text below may be used in the procurement of services from external suppliers to ensure that individuals with false ID documents or without work rights are not active in the premises and workplaces of the contracting party. The specification of requirements also aims to ensure that hired companies comply with laws and regulations regarding individuals' work rights.
The provider of this service must be able to demonstrate a verified and standardized process for identity and work rights verification for all employees performing work under this agreement. The process must be designed to ensure that all employees provided by the supplier have the right to work according to Swedish legislation.
- Visual Inspection
- The supplier must conduct a visual inspection of the presented identity documents to ensure they are genuine and match the individual's appearance.
- Technical Verification
- The supplier must use technical equipment to verify the authenticity of the documents. The verification must include comparison with known databases for security features.
- Validity Check
- The supplier must check that the documents are valid, not expired, or will not expire within the next four months.
Exclusion and qualification under the Public Procurement Act
- Mandatory exclusion grounds: a supplier must be excluded after a final conviction for, among others, participation in organized crime, corruption, money laundering, terrorist offences and human trafficking.
- Optional exclusion grounds: for example unpaid taxes and social security contributions, grave professional misconduct or bankruptcy.
- Qualification requirements: technical and professional ability as well as economic and financial standing.
- The checks also cover companies whose capacity is relied upon – and exclusion grounds can be checked for subcontractors as well.
Collective agreement conditions – in subcontractor tiers too
- Where needed, contracting organizations must impose labor law conditions on pay, holiday and working time at collective agreement level.
- The supplier is responsible for ensuring that engaged subcontractors meet the conditions of the contract.
- Follow-up can be done through self-reporting, document review and on-site checks.
- The more subcontractor tiers, the harder the checks become – and the greater the risk of unfair working conditions and labor market crime.
Checks where the work is performed
- Staff registers (personalliggare): required in construction, restaurants and vehicle service, among others – electronic staff registers apply on construction sites above a certain size.
- ID06: the industry standard for identification and attendance registration on construction sites.
- Identity and right to work: the employer has the formal duty to check, but it is the client who suffers when illegitimate tiers are let in. Enrollment checks at the gate catch false identities and missing permits.
- Posting of workers: foreign employers must register posted workers with the Swedish Work Environment Authority.
Critical operations: background checks of suppliers too
- The CER Directive and LOM (proposed to enter into force on 1 January 2027) mean that people in positions that a position analysis identifies as sensitive are to be background-checked – also when they are employed by suppliers and subcontractors.
- Put it in the contract: the supplier must be able to show that its staff are checked – identity, criminal record extract and a renewed check at least every two years.
How Sistec helps
Requirement specification for the procurement
Ready-made control requirements to include in the procurement documents, developed for clients with high personnel security demands.
Enrollment checks
Physical verification of identity, right to work and posting status before staff are given access to the workplace.
Continuous supplier checks
Checks of supplier and subcontractor staff through the Compliance Platform, with documentation and follow-up.
Background checks under CER
Criminal record extracts are reviewed at a physical meeting without storing copies, and the platform issues reminders when a renewed check is due.
Frequently asked questions about supplier checks
Before award, the contracting organization must check the exclusion grounds – for example convictions for economic crime as well as unpaid taxes and contributions – and that the supplier meets the qualification requirements.
The contracting organization must require the supplier to ensure that engaged subcontractors meet the imposed labor law conditions, and exclusion grounds can be checked for subcontractors as well. In practice, verifying who actually performs the work is the hardest part.
In construction, restaurants and vehicle service, among others. On construction sites above a certain size an electronic staff register is required.
The employer has the formal duty to check under the Aliens Act, but the client carries both risk and responsibility when the work is performed within its own operation. Enrollment checks with physical ID verification are the safest way to close the gap.
Under the proposal, critical operators are to background-check people in positions that a position analysis identifies as sensitive – including external staff. In practice this means the control requirements need to be passed on in supplier contracts and followed up continuously.
Secure the entire supply chain
Sistec verifies identity, right to work and background for supplier staff – from procurement requirements to enrollment at the gate and continuous follow-up.