RISQS Insurance Requirements UK | Evidence & Compliance
Why do RISQS insurance requirements catch out competent rail suppliers?
Because RISQS treats your insurance certificate as a dated compliance document, and when it expires you stop being visible to buyers. Most rail suppliers assume insurance is a background administrative item. On the RISQS portal it is live compliance evidence with an expiry date attached, sitting alongside management systems, competence and financial information. Let it lapse and your record goes non-compliant, which removes you from buyer searches under your RICCL codes. RISQS has reported an average of over 450 suppliers holding a non-compliant status in any given period. The commercial damage lands long before any insurance claim is ever made.
Key facts at a glance
- Expired evidence makes you invisible, not just flagged. RISQS has stated that where a requirement document expires, the supplier becomes invisible to potential buyers searching the portal. You do not get a warning banner next to your name — you simply stop appearing in the results.
- An average of 462 suppliers per period held non-compliant status in RISQS's 2024 financial year round-up, up from an average of 423 per period in 2022–23. This is not a rare administrative slip; it is a standing feature of the scheme.
- RISQS has cited over 50 requirement types that can cause a supplier to become non-compliant, with insurance among the most common. The scheme runs a monthly exercise chasing suppliers on expired requirements.
- RISQS is operated by RSSB and serves around 4,000 supplier members and 90-plus buyers including Network Rail, TfL, freight and passenger operators and the tier-one contractors. It is also a qualifying utilities dynamic market under the Procurement Act 2023, so your record has a procurement function as well as an assurance one.
- RICCL codes are the description of your business the whole industry sees. If your codes say you operate on-track plant and your insurance schedule says "general civil engineering contractor", you have created a documented, dated mismatch on a third party platform — and that is a fair presentation problem under the Insurance Act 2015.
- RISQS does not set universal limits of indemnity. It requires evidence appropriate to your codes. The limits that actually bind you come from your contracts, where £10m public liability and £10m employers' liability are commonly specified — above the £5m statutory floor in the Employers' Liability (Compulsory Insurance) Act 1969.
- The two-stage audit process changed the timetable. Audits are typically raised around 20 weeks in advance, with Stage 1 desktop evidence uploaded before a Stage 2 remote or face-to-face visit. If a full audit cannot be scheduled before your expiry date, RISQS has stated no extension is given and the audit status expires.
There is a particular kind of phone call that comes in three or four times a year. A rail contractor has been shortlisted for a package, the buyer has gone quiet, and when they chase it they are told their RISQS record is showing non-compliant. Nothing has gone wrong operationally. Nobody has had an accident. The business is profitable, competent and well run. An insurance certificate expired eleven days ago and the renewal document never made it onto the portal.
That is the whole failure. It costs nothing to prevent and it can cost a great deal to discover late, because by the time you find out, the expression of interest window has usually closed. This guide is about that specific problem: not whether your cover is adequate, but whether your compliance record proves it.
It is the companion piece to our full guide to rail contractor insurance, which deals with what your policy actually needs to cover — the railway exclusion, on-track plant, delay and disruption costs and the Network Rail joint-insured arrangement. Read that one for cover adequacy. Read this one for the record that proves it. Both sit behind our rail contractor insurance page.
What are the RISQS compliance states, and what does each one mean?
There are effectively four states, and only one of them makes you fully visible to buyers. Compliant with verification codes, compliant with audit-level codes, compliant with a limitation applied, and non-compliant. The gap that matters commercially is between the third and fourth: a limitation leaves you visible with a caveat buyers can see, while non-compliance removes you from searches under your RICCL codes entirely.
| State | How you get there | What buyers see | Commercial effect | Route back |
|---|---|---|---|---|
| Compliant — verification codes | Evidence submitted, checked and in date against verification-level RICCL codes | Full visibility against those codes | Can be invited to tender; no audit required for those codes | Maintain evidence in date |
| Compliant — audit-level codes | As above, plus a passed RISQS audit against the relevant protocol | Full visibility, with audit status | Access to higher-consequence work; a stronger underwriting presentation too | Maintain evidence and audit currency |
| Limitation applied | Missing or unaccepted third party certification for a code | Visible, with the limitation and its reason shown | Buyers may assure the product themselves or require it contractually | Submit appropriate assurance at any time to remove it |
| Non-compliant | Expired requirement document, or an unresolved major non-conformance | Invisible in buyer searches under your RICCL codes | You are not found, not shortlisted, not invited — usually without being told | Upload current evidence or close out the non-conformance |
The asymmetry to understand. A limitation is a visible caveat — irritating, but you are still in the results and a buyer can weigh it. Non-compliance is silence. Nobody rings to tell you that you did not appear in a search. That is why insurance evidence expiry is disproportionately damaging relative to how trivial it is to prevent.
What is RISQS and who actually runs it?
RISQS is the Railway Industry Supplier Qualification Scheme, operated by RSSB on behalf of the GB rail industry. It is the entry point for suppliers into the rail supply chain: buyers use it to assure suppliers before engaging them, so for many types of work RISQS registration is a prerequisite for being considered at all. Around 4,000 supplier members serve 90-plus buyers. Importantly, RISQS enables access — it does not guarantee work, and it is not a mark of quality in isolation.
The scheme exists to solve a duplication problem. Without it, every rail buyer would audit every supplier separately, and a mid-sized contractor working for Network Rail, TfL, two freight operators and three tier-one contractors would spend most of its year being audited. RISQS consolidates that into one assurance process the whole industry recognises.
Three structural points matter for how you manage your insurance evidence:
- It is sponsored by the industry, not by one buyer. The scheme is governed by a committee of industry representatives reporting into RSSB. That is why the requirements are not negotiable with any individual client — your buyer cannot waive them for you.
- It is a procurement mechanism as well as an assurance one. As a qualifying utilities dynamic market under the Procurement Act 2023, subscribing buyers use it to select suppliers for invitation to tender. Your record is not just a safety file; it is your position in a live procurement list.
- Buyers are actively notified about you. RISQS operates a "watch" function that notifies a buyer where a supplier they work with has a non-conformance. Compliance problems do not stay quiet within your own organisation.
What insurance evidence does RISQS require you to upload?
Current certificates for the liability lines relevant to the RICCL codes you have selected, with valid expiry dates recorded on the portal. In practice that means employers' liability, public and products liability, and — where you carry design, advisory or engineering assurance responsibility — professional indemnity. Motor and plant evidence may be required depending on your codes. The evidence sits in the same compliance set as management systems, competence management and financial information, and it is quality-checked by the RISQS team rather than simply accepted on upload.
The three things that go wrong at upload
The certificate is in date but the wrong document. An employers' liability certificate is a statutory document with its own format; a public liability certificate is not, and what your insurer issues may be a summary, a schedule extract or a broker letter. Which of these the portal accepts is not always obvious, and a rejected document can leave a requirement sitting unmet while you believe it is done.
The policy period and the portal record drift apart. Mid-term changes — a new insurer after a market move, a limit increase to satisfy a contract, an activity added to the schedule — generate new documents that nobody uploads because the renewal date has not arrived. The portal continues to show the superseded document until its original expiry, at which point the record fails against paperwork you replaced months ago.
The named insured does not match the registered supplier. Group structures, trading names and recently incorporated entities routinely produce a certificate in one name and a RISQS registration in another. It is a five-minute fix at issue and a genuine obstacle at audit.
The fix is procedural, not technical. Ask your broker to send renewal documents to whoever administers your RISQS portal on the same day they are issued — not to accounts, not to the director's inbox. Then ask for certificates to be issued with an anniversary that suits your record. It removes an entire category of avoidable commercial damage and costs nothing.
What happens when your insurance evidence expires?
Your record goes non-compliant and you disappear from buyer searches under your RICCL codes. RISQS has stated plainly that expired requirement documents lead to suppliers becoming invisible to potential buyers on the portal. The scheme runs a monthly chase exercise contacting affected suppliers, but that is a courtesy, not a safety net — the invisibility takes effect regardless, and the buyer who did not find you has no reason to tell you.
It is worth sitting with the scale of this. In its 2024 round-up RISQS reported an average of 462 suppliers per period holding non-compliant status, having reported an average of 423 per period two years earlier. These are not fly-by-night operators. They are ordinary rail businesses whose paperwork slipped, in a scheme where paperwork slipping means commercial invisibility.
Three consequences follow, in order of how quickly they bite:
- You stop being found. Buyers searching under a RICCL code for an expression of interest will not see you. There is no notification of the tenders you were not invited to.
- Existing buyers get notified. Where a non-conformance is involved, the watch function tells buyers you already work with. That is a relationship conversation you did not plan for.
- The gap becomes a disclosure question. If you were genuinely uninsured rather than merely un-evidenced, that is a different and much more serious problem — and one your next insurer will ask about. Our guide to insurance cancelled by your insurer covers how gaps in cover are treated at renewal.
From recent placement conversations
"The question I get asked is 'will this certificate pass RISQS'. It is almost always the wrong question. The certificate will almost always upload. What nobody checks is the two things either side of it — whether the policy behind the certificate actually covers the work described by the codes, and whether anyone has a diarised job to put the next certificate on the portal."
"I have had a contractor lose a place on a framework shortlist over a nine-day evidence gap. Fully insured the entire time. The cover was never in question for a second. They just were not visible in the search that mattered, in the week that mattered, and nobody rang to tell them. That is a business development loss caused entirely by an administrative process nobody owned."
How does the Insurability Framework apply to RISQS compliance?
Your RISQS record is underwriting evidence, not just procurement evidence. Audit-level codes, clean audit outcomes and an unbroken compliance history are independent third party proof of competence — exactly the material that moves a rail underwriter. Placing rail work is exactly what The Insurability Framework™ was built for, and the RISQS record is one of the strongest inputs it uses.
The Insurability Framework applied to your RISQS record
How we turn compliance evidence you already hold into better terms.
Most brokers never ask to see your RISQS record. Rail underwriters treat audit-level codes and clean audit outcomes as independent verification of competence — which is worth more in a submission than any amount of self-description. We put it front and centre.
Where a policy has to be written to match specific RICCL codes rather than a generic trade description, general markets refer or decline. Rail-aware Lloyd's syndicates and specialist MGAs will write to the codes, which is what makes the evidence hang together.
The mismatch between your codes and your policy wording is a fair presentation exposure hiding in plain sight on a public platform. We map one against the other before renewal, so the two documents tell the same story.
If a claim is investigated, your RISQS record is early disclosure material. A record that corroborates your presentation strengthens the claim; one that contradicts it is the first thing an investigator finds. We keep them aligned from the outset.
More on the method on our Insurability Framework page, and on comparable placements in our adverse risk insights hub.
Why must your RICCL codes match your policy wording?
Because the codes are a dated, public declaration of what your business does, and your insurer is entitled to rely on a different one. The Rail Industry Commodity Classification List is how the industry classifies products and services; you select the codes describing what you supply. If those codes describe activities your policy schedule does not mention, you have created a documented inconsistency between what you told the industry and what you told your insurer — and under the Insurance Act 2015 a commercial policyholder owes a duty of fair presentation.
This is the single most under-appreciated exposure in rail compliance, and it is worth being precise about why it bites so hard.
A fair presentation argument normally turns on what a business knew and whether it disclosed it. Those arguments are usually messy, because the evidence is internal and contemporaneous records are thin. RISQS changes that. Your codes are selected deliberately, recorded with a date, visible to buyers, and maintained by you. If your codes say you undertake on-track plant operations and your insurance schedule describes you as a general civil engineering contractor, the inconsistency is not a matter of interpretation. It is documented on a third party platform, and it is the first thing any claims investigator will pull.
How to reconcile the two
- Export your codes. The portal allows you to export your RICCL selections. Do it once a year, before renewal, not after.
- Read them against your policy schedule line by line. Not the certificate — the schedule, where the business description and any activity endorsements live.
- Flag anything the schedule does not obviously cover. Design and advisory work, on-track plant, work at height, labour supply and anything trackside are the usual suspects.
- Fix it at renewal, in writing. Get the activity added to the schedule, and keep the correspondence. A disclosure made and documented is worth far more than one made verbally and forgotten.
- Do the same in reverse. If you hold codes for work you no longer do, remove them. Carrying dormant codes invites underwriting questions you do not need and misrepresents your business to buyers.
Where this most often shows up. Businesses that started outside the boundary fence and grew inwards. A groundworks or vegetation firm adds a code to win a package, does the work competently, and never revisits the insurance schedule written for its original trade. The wider version of this problem — the railway exclusion itself — is covered in our rail contractor insurance guide, and the adjacent trades are covered in our groundworks contractor guide and tree surgeon and arboriculture guide.
What limits of indemnity does RISQS actually require?
RISQS does not set universal limits — your contracts do. The scheme requires evidence appropriate to your selected codes, quality-checked and in date. The numbers that bind you appear in sub-contract insurance schedules, where £10m public liability and £10m employers' liability are commonly specified, with higher limits on major projects and tier-one frameworks. Pricing a job against your existing certificate rather than the contract schedule is how contractors end up committing to limits they do not hold.
The practical sequence is: read the contract, then check the certificate, then quote the job. Contractors routinely do this in the opposite order, and the mismatch surfaces after the price is agreed — at which point the extra premium comes out of the margin.
Beyond the headline limits, four things in a rail sub-contract schedule regularly exceed what a standard policy delivers:
- Indemnity to principal or joint insured status for the buyer and its group companies.
- A waiver of subrogation, which requires your insurer's agreement and should never be accepted without it.
- A contractual deductible higher than your own policy excess, leaving you self-insuring the difference.
- Professional indemnity maintained for a stated period after completion, which becomes a run-off obligation if you stop trading — see professional indemnity run-off cover.
What evidence does your type of rail supplier need?
The evidence set follows your codes, and the codes follow what you actually do. Select the closest match below for the compliance and cover priorities we would build.
RISQS evidence checker
Rail civils, earthworks and structures
- LEGAL Employers' liability certificate, current and in the registered supplier's exact name.
- ESSENTIAL Public and products liability evidence at the limits your contracts specify, with the railway written into the schedule as a permitted activity.
- CRITICAL Codes and schedule reconciled — trackside and possession working must appear in both, not just one.
- RECOMMENDED Contract works and plant evidence where your codes cover temporary works or equipment.
- CONSIDER Whether your codes are verification or audit level — see the audit protocol section below before assuming.
On-track plant and road-rail vehicle operators
- CRITICAL Plant cover that operates while the machine is on rails — many general plant wordings exclude it or are silent, and silence is worse.
- LEGAL Employers' liability at rail market limits given the injury profile of machine operations under possession.
- ESSENTIAL Motor evidence for the road leg of dual-mode machines, correctly rated for on-track use.
- ESSENTIAL Public liability with the railway extension and indemnity to principal.
- RECOMMENDED Plant schedule kept current — see our plant and machinery insurance guide.
Design consultancies and engineering assurance
- CRITICAL Professional indemnity evidence, with the retroactive date protected across every renewal and insurer change.
- CRITICAL Post-completion maintenance obligations checked — many appointments require PI for years after handover.
- LEGAL Employers' liability wherever you employ anyone, including staff attending site for surveys or witnessing.
- ESSENTIAL Public liability for site attendance at the limits your access agreements demand.
- CONSIDER Whether any appointment imports a fitness-for-purpose obligation, which sits outside a PI policy that insures negligence. See professional indemnity insurance.
Lineside vegetation management and fencing
- CRITICAL Confirmation that climbing and work at height are covered, not only ground-level clearance — many trades schemes cap this.
- ESSENTIAL Public liability with the railway extension; lineside work sits inside a proximity exclusion almost by definition.
- LEGAL Employers' liability at rail limits given chainsaw work beside a live railway.
- RECOMMENDED Herbicide and pollution evidence where your codes cover weed control on ballast or cess.
- CONSIDER The boundary with general arboriculture, set out in our tree surgeon insurance guide.
Rail labour supply and Sentinel sponsors
- LEGAL Employers' liability reflecting the correct employment status of every worker — agency, PAYE and self-employed are treated differently.
- CRITICAL Labour-only supply declared as an activity on the schedule; supplying labour under another's direction changes the liability analysis.
- CRITICAL Sentinel sponsorship governance, competence records and drug and alcohol testing data current — the Sentinel protocol is generated alongside audit where you work trackside.
- ESSENTIAL Public liability including liability for the acts of supplied personnel.
- CONSIDER Professional indemnity where you also supply safe work planning or competence assurance rather than personnel alone.
Product, component and material suppliers
- CRITICAL Products liability at limits proportionate to where the component ends up, not to its unit price.
- ESSENTIAL Third party product certification where your RICCL code requires it — its absence is a common cause of a limitation being applied.
- LEGAL Employers' liability for manufacturing and warehouse staff.
- RECOMMENDED Product recall cover where a defect would require withdrawal from the network — see our product recall insurance guide.
- CONSIDER Efficacy and performance exposure where a component's failure causes disruption rather than damage.
Is your RISQS insurance record at risk right now?
Tick anything below that is true of your business today. Each one is a live cause of the non-compliant status that removes suppliers from buyer searches.
RISQS compliance risk checklist
- No single named person owns uploading insurance documents to the portal.
- You cannot say today, without checking, when your portal insurance evidence expires.
- You changed insurer mid-term in the last 12 months and are not certain the new documents were uploaded.
- Your limits were increased to satisfy a contract but the portal still shows the old certificate.
- The certificate is issued in a trading name or group entity that differs from your RISQS registration.
- You have never exported your RICCL codes and read them against your policy schedule.
- You hold codes for activities you no longer carry out.
- You have added trackside or possession working since your policy was last rewritten.
- You carry design or temporary works responsibility but hold no professional indemnity.
- You have an open non-conformance from a previous audit that has not been formally closed out.
- Your audit target date is within 20 weeks and Stage 1 evidence has not been started.
- Your renewal date and your audit expiry date fall close together with no plan for the overlap.
Two or more ticks is enough to lose a tender you never knew you were considered for. Every item on this list is fixable in an afternoon; none of them is fixable retrospectively once a buyer's search has already run.
How exposed is your RISQS record to a compliance gap?
RISQS compliance exposure assessor
How do RISQS audits work in 2026?
In two stages, with roughly 20 weeks of notice. Audits are typically raised around 20 weeks before the target date, and from that point the requirements appear on your portal. Stage 1 is a desktop review where you upload policies and procedures in advance; Stage 2 is the audit itself, delivered remotely or face to face, focused on the areas needing clarification or deeper review. The content of the audit did not change when the two-stage process came in — what changed is that unprepared suppliers now have nowhere to hide the gaps.
RISQS introduced the two-stage approach to let auditors concentrate on high-risk evidence rather than spending Stage 2 time on document collection, and to align the scheme with comparable assurance schemes elsewhere in industry. A year on, it has published clarifications aimed at making the process more consistent, so if your last audit predates the change, expect a different rhythm.
Three operational points that catch suppliers out:
- The 20-week window is preparation time, not waiting time. Everything required appears on the portal when the audit is created. Suppliers who start at week 18 have a comfortable audit; suppliers who start at week 2 do not.
- Opting out of the desktop stage is expensive. RISQS has stated that requesting a full audit without the Stage 1 desktop requirement results in the current lead audit being cancelled, cancellation fees applied and a new date scheduled.
- There is no extension for running out of road. Where a full lead audit cannot be scheduled before the supplier's expiry date, RISQS has stated no extension is given and the audit status expires. That converts a scheduling problem into a compliance problem.
Watch the collision between your audit expiry and your insurance renewal. If they fall within a few weeks of each other, you have two independent expiry mechanisms pointing at the same record, each capable of making you invisible. Map both dates on one calendar and manage the earlier one first.
Which RISQS protocol applies to your business?
It depends on whether you work inside the operational railway, and whether you work trackside. RISQS operates separate protocols for non-operational railway services and Operational Railway Services, with the Sentinel protocol generated alongside for trackside work. A supplier audited on the non-operational protocol who then intends to work inside the operational boundary needs an out-of-turn audit against the operational protocol — you cannot simply start doing the work.
This mirrors the insurance boundary almost exactly, which is why the two documents should be reviewed together. The moment your business moves inside the operational boundary, three things change simultaneously: the RISQS protocol you are audited against, the RICCL codes you need, and whether your liability policy's railway exclusion has any effect. Contractors typically notice the first, are told about the second by a buyer, and discover the third during a claim.
RISQS has also introduced additional protocols in recent years, including Road Risk and Sustainability, reflecting how the scheme's scope has broadened beyond core safety assurance. Where you hold codes touching those areas, expect the evidence set to be wider than the traditional liability certificates.
The out-of-turn audit is the tell. If a buyer has asked you to undertake an out-of-turn audit against the operational protocol, that is your prompt to have the insurance schedule reviewed at the same time. The business has changed shape; both documents need to catch up together. Our rail contractor insurance page sets out how we handle that transition.
What are the most common RISQS non-conformances?
Management system failures dominate, not technical rail failures. RISQS has repeatedly flagged monitoring and measuring (section 8.1) as a common source of major non-conformance, driven by inadequate monitoring systems and failure to address previous audit findings, and has identified inconsistently applied supplier assurance and monitoring processes among recurring themes. In the 2024 financial year RISQS recorded 231 major and 1,190 minor non-conformances; in 2022–23 it recorded 389 major non-conformances across 154 organisations.
The pattern in that data is worth reading carefully, because it tells you where the effort should go. Suppliers tend to prepare for audits by getting their technical documentation in order — method statements, risk assessments, competence records. Those are rarely where the majors land. The majors land on whether you can demonstrate a working system for monitoring your own performance, and whether you actually closed out what the last audit told you.
Two rules that prevent most of the avoidable findings
A statement of intent is not a process. RISQS has been explicit that a statement of intent presented at audit which is not an adequate process will lead to a non-conformance. Describing what you would do is not evidence of what you do. Auditors want the record showing it happened.
"Not applicable" needs justification. Where a requirement does not apply to your organisation, you must provide adequate justification, and it is recorded in the audit report. Failure to justify adequately leads to a non-conformance in its own right. Silence is not an answer.
There is also a compounding effect worth naming. Failure to address previous audit findings is itself cited as a driver of major non-conformances — so an unclosed minor from last time does not sit still. It escalates. Early, documented close-out is the cheapest compliance activity available to you.
How does your RISQS status affect what you pay for insurance?
More than most suppliers realise, because rail underwriting is judgement-led and RISQS is independent evidence. An underwriter deciding whether to write a rail risk is trying to establish competence and control. Audit-level codes, a clean audit history and an unbroken compliance record do that work in a way self-description cannot. Ambiguity, by contrast, gets priced — so a supplier who cannot explain their own record pays for the uncertainty.
| Factor | Why the underwriter cares | What improves your position |
|---|---|---|
| Audit-level vs verification-only codes | Audit-level codes mean an independent auditor has tested your systems | Present the audit outcome, not just the fact of registration |
| Audit history and outcomes | Repeat majors suggest a management system problem, not bad luck | A clean run, or a clear narrative of what changed after a finding |
| Open non-conformances | An unclosed finding is a live, documented, third party criticism | Close out and evidence it before you go to market |
| Compliance continuity | Historic non-compliant periods raise questions about whether cover lapsed too | Be able to show the gap was evidential, not a gap in cover |
| Code-to-schedule alignment | A mismatch is a fair presentation exposure the insurer inherits | Reconcile before renewal and document the disclosure |
| Protocol level | Operational Railway Services and Sentinel indicate trackside exposure | Declare it deliberately rather than letting it be discovered |
| Sentinel sponsorship governance | Competence and drug and alcohol regime quality predicts EL claims | Sponsorship policy, competence matrix and testing records |
| Monitoring and measuring maturity | The most cited major non-conformance area across the scheme | Evidence of a working system, with records not intentions |
| Subcontractor assurance | Your liability follows your sub-contractors' failures | Verified sub-contractor insurance and minimum limits imposed downward |
| Claims record — frequency | Frequency predicts management quality more reliably than severity | Three to five clean years with documented root cause analysis |
| Claims record — severity | One serious rail loss reshapes the whole submission | A full narrative of what changed afterwards, not just the loss run |
| Contractual liability caps | Uncapped delay liability is unquantifiable and priced defensively | Negotiated caps, and evidence you review schedules before signing |
| Presentation quality | Rail underwriting is judgement-led; ambiguity is expensive | A structured broker submission that answers questions before they are asked |
The point most suppliers miss. You have already paid for the RISQS audit. The evidence it produced is sitting on a portal doing procurement work. Using it a second time, in an insurance submission, costs nothing and materially changes how an underwriter reads your business. Almost nobody does this, which is precisely why it works.
What does a RISQS compliance failure actually cost?
The three examples below are illustrative composites written for this guide. They are not real clients and not actual claims; the figures are indicative of the shape and scale of loss in this area, not settlements we have handled. They are included because compliance failures produce commercial losses that never appear in a claims file, and so are systematically under-appreciated.
Case study 1 — The nine-day window
The situation. A rail civils contractor renewed its liability programme on 1 June. The certificates were issued to the managing director's inbox and forwarded to accounts for the premium payment. Nobody uploaded them to the RISQS portal, where the previous documents expired on 31 May.
The consequence. The record went non-compliant on 1 June. On 4 June a tier-one contractor ran a RICCL search for an expression of interest on a station package worth roughly £480,000 to the successful sub-contractor. The business did not appear. The documents were uploaded on 9 June after a routine RISQS chase email. The EOI window had closed on 6 June.
The cover position. Cover was continuous throughout. There was no insurance gap of any kind, no claim, and nothing that would ever appear on a loss run. The failure was entirely evidential.
The lesson. Nobody rings to tell you that you were not in the search results. The business only learned what had happened because a contact at the tier-one mentioned it informally months later. Fix applied: broker now sends renewal documents directly to the named portal administrator on the day of issue, with the expiry date diarised 30 days ahead.
Case study 2 — The code that outgrew the policy
The situation. A fencing and vegetation contractor added RICCL codes covering trackside working to win a lineside package. The codes were selected in February. The liability policy, written when the business worked exclusively on highway and industrial sites, described the business as "fencing contractor" and carried a clause restricting work within a stated distance of an operational railway.
The consequence. Eleven months of trackside work was carried out under a policy whose wording did not contemplate it. A minor incident — debris entering the cess, no injury, no service disruption — triggered a coverage review during which the insurer obtained the RISQS record and identified the code selection date.
The cover position. The insurer raised fair presentation under the Insurance Act 2015, arguing the business had declared trackside working to the industry in February and to its insurer never. The claim itself was modest at around £14,000, but the coverage argument put the whole year's trading at risk. It settled with a proportionate reduction and the policy was rewritten mid-term at an additional premium of roughly £9,600.
The lesson. The RICCL code selection is a dated declaration. It is the single most useful document a claims investigator can find, and it is one you created. Renewal impact: premium roughly doubled once the activity was correctly declared, which is what it should always have cost.
Case study 3 — The unclosed minor
The situation. A multi-disciplinary rail contractor received two minor non-conformances at audit relating to monitoring and measuring. Both were acknowledged and neither was formally closed out, on the basis that they were minor and the next audit was two years away.
The consequence. At the following audit the same areas were examined, no evidence of corrective action existed, and the findings were escalated to major. The supplier's status was affected while close-out was completed, during a period that overlapped a framework re-tender.
The knock-on. At the next insurance renewal the underwriter asked for the audit history. The escalation from minor to major, driven by non-closure rather than by any new failure, read as a management system weakness rather than an isolated finding. Terms were offered with a higher excess and a loading of approximately 18%.
The lesson. Findings do not sit still — failure to address previous audit findings is itself a driver of majors. And your audit history is read by more people than you think. Fix applied: formal close-out register with named owners and evidence attached, presented at the following renewal to reverse the loading.
How do you keep your RISQS insurance record clean?
Give it an owner, a diary and a direct document route — in that order. Almost every compliance failure in this area traces back to nobody specifically owning the upload. Name a person, diarise every expiry 30 days ahead, have your broker send documents straight to that person on issue, and reconcile your RICCL codes against your policy schedule once a year before renewal. The whole system takes an afternoon to set up and prevents the entire failure class.
- Name one portal administrator. One person, named in writing, responsible for every requirement upload. Shared responsibility is the single strongest predictor of a lapse.
- Build a live expiry register. List every requirement with an expiry date — insurance, certifications, audit status — in one place, with alerts 30 days ahead. Two independent expiry mechanisms can each make you invisible; both need to be on the same calendar.
- Instruct your broker to send documents direct. On the day of issue, to the named administrator, for renewals and mid-term changes alike. Mid-term insurer changes and limit increases are where records most often drift.
- Export and reconcile your RICCL codes annually. Read them against the policy schedule, not the certificate. Flag anything the schedule does not clearly cover, and remove codes for work you no longer do.
- Document every disclosure in writing. When an activity is added to the schedule, keep the correspondence. A documented disclosure is worth far more than a remembered conversation if fair presentation is ever argued.
- Start Stage 1 evidence the week the audit appears. Everything required is visible from around 20 weeks out. Preparing early converts the audit from an examination into a review.
- Close out every finding formally, including minors. Record the corrective action, attach the evidence, name the owner and date it. Unclosed findings escalate at the next audit and read badly to underwriters.
- Reuse the record at renewal. Give your broker your audit outcomes and code list as part of the submission. You have already paid for the evidence; it should be working in two places.
John Miller — Director & Principal Broker
John has spent over thirteen years placing specialist commercial risks, with a particular focus on infrastructure businesses whose activities sit outside standard market appetite. Rail suppliers are a recurring example: firms lose tender visibility over evidence gaps that have nothing to do with the quality of their cover, and lose coverage arguments over inconsistencies between their RICCL codes and their policy schedules. He works with civils, plant, vegetation, signalling, design and labour supply businesses across the rail supply chain to keep those two documents telling the same story — and to make the compliance evidence they have already paid for work harder at renewal.
Former #1 Account Executive at Brown & Brown and former #1 Salesperson at AXA, with direct access to the Lloyd's Market and specialist MGA schemes.
Glossary of RISQS and rail compliance terms
- RISQS
- The Railway Industry Supplier Qualification Scheme, operated by RSSB. The qualification route into the GB rail supply chain, used by buyers to assure suppliers before engagement.
- RSSB
- The Rail Safety and Standards Board, which operates RISQS on behalf of the industry and maintains the RICCL.
- RICCL
- Rail Industry Commodity Classification List. The standardised classification of products, services and materials used across the network. Suppliers select codes describing what they supply.
- Verification code
- A RICCL code whose risk level requires evidence to be submitted and checked, but no audit. Registration completes on successful verification.
- Auditable code
- A RICCL code whose risk level requires the supplier to undergo and pass a RISQS audit before being qualified to supply against it.
- Limitation
- A marker applied where required third party certification is absent or not accepted. The supplier stays visible, but buyers see the limitation and its reason, and may arrange their own assurance.
- Non-compliant status
- The state resulting from expired requirement documents or unresolved non-conformances. The supplier becomes invisible to buyers searching under their RICCL codes.
- Non-conformance
- An audit finding, classified major or minor. Unclosed minors can escalate to majors at the following audit.
- Two-stage audit
- The current RISQS audit format. Stage 1 is a desktop review of documentation uploaded in advance; Stage 2 is the audit itself, remote or face to face, focused on areas needing further review.
- Out-of-turn audit
- An audit undertaken outside the normal cycle, required for example where a supplier assured for non-operational railway services intends to work within the operational boundary.
- Operational railway
- The part of the network in operational use. Working within its boundary changes the applicable protocol, the codes required, and whether a liability policy's railway exclusion has effect.
- Sentinel
- The industry scheme recording competence, sponsorship and drug and alcohol testing data for personnel working on Network Rail infrastructure. A Sentinel protocol is generated alongside audit for trackside work.
- Watch function
- The RISQS mechanism notifying a buyer where a supplier they work with has a non-conformance.
- Qualifying utilities dynamic market
- The procurement status RISQS holds under the Procurement Act 2023, allowing subscribing utilities to select suppliers for invitation to tender.
- Fair presentation
- The duty owed by a commercial policyholder under the Insurance Act 2015 to disclose material circumstances. RICCL codes are dated evidence of what a business told the industry it does.
- Retroactive date
- The date in a claims-made professional indemnity policy before which work is not covered. Changing insurer can reset it, leaving past rail design work uninsured.
Frequently asked questions
What insurance does RISQS require?
RISQS requires current insurance evidence appropriate to the RICCL codes you have selected, uploaded to the portal with valid expiry dates. In practice that means employers' liability, public and products liability, and professional indemnity where you carry design or advisory responsibility. Motor and plant evidence may be required depending on your codes. It sits in the same compliance set as management systems, competence management and financial information.
Does RISQS set minimum limits of indemnity?
No. RISQS requires evidence appropriate to your codes rather than imposing universal limits. The figures that bind you come from your contracts, where £10m public liability and £10m employers' liability are commonly specified, with higher limits on major projects. The statutory floor for employers' liability is £5m, but it is rarely enough for a rail sub-contract. Always price the job against the contract schedule.
What happens if my insurance evidence expires on the RISQS portal?
Your record becomes non-compliant and you become invisible to buyers searching the portal under your RICCL codes. RISQS runs a monthly exercise contacting suppliers with expired requirements, but the invisibility applies regardless, and buyers who did not find you have no reason to tell you. RISQS reported an average of 462 suppliers per period holding non-compliant status in its 2024 financial year.
How quickly can I fix a non-compliant RISQS status?
Where the cause is an expired document, uploading current evidence is the fix and it can be resolved quickly. Where the cause is an unresolved non-conformance, you need to complete and evidence the corrective action, which takes longer. Either way the commercial damage from the period of invisibility cannot be recovered — the tenders you were not invited to have already been issued.
What is the difference between verification and auditable RICCL codes?
Each code carries a pre-set risk level. Verification codes complete on submission and checking of evidence, with no audit required. Auditable codes require your organisation to undergo and pass a RISQS audit before you are qualified to supply against them, reflecting higher safety consequence. Audit-level codes also make a materially stronger insurance submission, because an independent auditor has tested your systems.
Do my RICCL codes affect my insurance?
Yes, in two ways. They are a dated, public declaration of what your business does, so a mismatch between your codes and your policy schedule is a fair presentation exposure under the Insurance Act 2015 that a claims investigator will find immediately. They also shape what cover you actually need — codes covering trackside work, on-track plant or design responsibility each require specific policy features that a general contractors' policy will not have.
How does the RISQS two-stage audit work?
Audits are typically raised around 20 weeks before the target date, and the requirements appear on your portal from that point. Stage 1 is a desktop review of policies and procedures you upload in advance. Stage 2 is the audit itself, remote or face to face, concentrating on areas needing clarification or deeper review. The audit content did not change with the new format; the preparation timetable did.
Can I opt out of the Stage 1 desktop review?
RISQS has stated that requesting a full audit without the desktop requirement results in the current lead audit being cancelled, cancellation fees being applied and a new lead audit date being scheduled. It has also stated that where a full lead audit cannot be scheduled before the supplier's expiry date, no extension is given and the audit status expires. In practice, opting out is an expensive route to a compliance problem.
What are the most common reasons suppliers fail a RISQS audit?
Management system weaknesses rather than technical rail failures. RISQS has repeatedly identified monitoring and measuring as a common source of major non-conformance, driven by inadequate monitoring systems and failure to address previous audit findings, and has flagged inconsistently applied supplier assurance processes. It has also been explicit that a statement of intent which is not an adequate process will itself lead to a non-conformance.
Does RISQS registration mean I am insured correctly for rail work?
No, and this is the most dangerous assumption in the sector. A certificate can upload cleanly and satisfy the portal while the policy behind it excludes work on or near an operational railway. RISQS checks that you have evidence; it does not check that the wording responds to your work. Our rail contractor insurance guide covers the railway exclusion and what a policy needs to say.
Do I need an out-of-turn audit if I start working trackside?
If you were assured under the non-operational railway services protocol and intend to work within the operational boundary, RISQS has stated an out-of-turn audit against the Operational Railway Services protocol is required, generated alongside the Sentinel protocol for trackside work. That is also the moment to have your insurance schedule reviewed, because the same boundary change determines whether your policy's railway exclusion bites.
Can a broker help with my RISQS insurance evidence?
A specialist one should. That means issuing certificates in the exact registered supplier name, aligning the renewal anniversary with your portal record, sending documents direct to your named administrator on the day of issue, and reconciling your RICCL codes against your policy schedule before renewal rather than after a claim. Miller & Partner approaches every rail placement through the Insurability Framework — underwriter intelligence, difficult risk expertise, risk assessment and claims advocacy. Start at our rail contractor insurance page or call 01792 001350.
About this guide
This guide is general information about insurance and compliance evidence for UK rail suppliers. It is not advice, and it is not a recommendation to buy or hold any particular policy. Any cover described is subject to insurer acceptance, underwriting and the terms of the policy actually issued.
Miller & Partner is not affiliated with RISQS or RSSB, and this guide is not an official description of the scheme. Scheme requirements, protocols and processes are described from published sources as at the publication date and may change — always check the current position with RISQS directly for your own registration.
The case studies are illustrative composites written for this guide. They are not real clients and not actual claims; the figures are indicative and are not settlements handled by Miller & Partner. The interactive evidence checker, checklist and exposure assessor are general information tools only — not personalised advice, not a recommendation and not a quotation.
Legislation and regulatory guidance are described as at the publication date shown at the top of this guide and may change. For our regulatory status, please see the footer of this website. To discuss a rail placement, email enquiries@millerandpartner.co.uk or call 01792 001350.
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