Transport Subcontractor Vetting: A Checklist for SA

Published: 30 October 2026

Transport subcontractor vetting is the process of checking a sub-hauler before they carry a load for you, and keeping that check current for as long as you use them. Most South African transport operators subcontract at some point, whether to cover peak harvest or coal volumes, a breakdown, or a lane they do not run themselves. The truck on the road carries your client's goods and often your name on the paperwork. When it is overloaded, unroadworthy or driven by someone without a valid permit, the consequences land on you as well: client penalties, a lost contract, an RTMS finding, or a legal exposure under the consignor and consignee regulations.

This guide covers what the law actually requires of the parties to a load, what to check before a sub-hauler's first trip, how to keep checking once they are working, and how to set up the paperwork so you can prove it. It focuses on the subcontractor relationship. For certifying your own operation, see the RTMS hub and our RTMS audit checklist.

Why Does Subcontractor Vetting Matter for SA Transporters?

Clients do not see your subcontractor. They see their load, their delivery window and your invoice. If a sub-hauler's truck is stopped at a weighbridge, breaks down with an expired roadworthy, or is involved in a crash, the client asks you what went wrong and why you used that truck.

The risks fall into four groups:

• Legal. Since 31 January 2015 the National Road Traffic Regulations have placed specific duties on consignors and consignees (regulations 330A to 330D, covered below). If you broker or subcontract loads, you may be acting as a consignor, or contracting with one who expects you to carry those duties for them.
• Contractual. Mines, manufacturers and large shippers often write subcontracting rules into their transport agreements, such as prior approval of sub-hauliers, RTMS certification or flow-down of their site rules.
• Insurance. Your own goods-in-transit and liability policies may exclude or restrict loads carried by third parties. Only your broker can confirm what your policy says.
• Certification and reputation. Under the RTMS standard, subcontractor vehicles are only in your certification scope if you choose to include them, but any you include must meet every requirement. Clients who are consignors under the standard also evaluate the transporters they use, and that evaluation follows you.

What Do Regulations 330A to 330D Require of Consignors and Consignees?

The consignor and consignee regulations were inserted into the National Road Traffic Regulations by Government Notice R. 846 of 2014, with effect from 31 January 2015. In plain terms:

| Regulation | What it requires | What it means when you subcontract |
|---|---|---|
| 330A - Offering and accepting goods | A consignor or consignee may not offer or accept goods on a vehicle that is not loaded in line with the Act. The consignor must get a written statement from the operator on the vehicle's payload and load distribution. Neither may contract with an operator to carry goods on a vehicle that would be overloaded. | Get each sub-hauler's payload and axle configuration in writing for every vehicle you will use, and do not book a load the vehicle cannot carry legally. |
| 330B - Method of determining mass | The consignor must use an accurate method to establish vehicle and axle mass, keep a record of the mass of every load leaving its premises, and make the record available to traffic officers. | Weigh at origin where you can, keep the weighbridge slip with the trip, and expect your client's records to be checked against yours. |
| 330C - Goods declaration | A goods vehicle on a public road must carry a declaration with the vehicle licence numbers, nature and quantity of goods, operator, consignor and consignee details, a written transport agreement covering loading instructions and each party's responsibilities, and a schedule of insurance. | The sub-hauler's driver needs this declaration for your loads too. Issue it from your system, not by hand at the gate. |
| 330D - Insurance | A consignor or consignee may not transport or accept goods unless the transportation is fully insured for damage that can result from an incident. | Ask for proof of cover from the sub-hauler and check how your own policy treats subcontracted loads. |

The regulation 330C requirement for a written agreement is important for subcontracting. It means a handshake arrangement with a sub-hauler is not just poor practice: the declaration on the truck is supposed to reflect a written agreement that sets out loading instructions and responsibilities.

These duties sit alongside, not instead of, the operator's own obligations. Overloading fines are covered in our overloading fines schedule guide. Because the declaration carries names and addresses of natural persons, handle it in line with POPIA, as discussed in our POPIA and driver data post.

What Should a Transport Subcontractor Vetting Checklist Include?

Vet before the first load, not after. The checklist below is our recommended minimum for a sub-hauler running goods vehicles over 3,500 kg GVM on public roads. Adjust it to your clients' requirements and the type of freight.

| Area | Check | Evidence to hold | When to re-check |
|---|---|---|---|
| Company | Registered business, tax status, banking details confirmed | CIPC registration, tax compliance status PIN, bank confirmation letter | Annually, and on any change of bank details |
| Operator registration | Each vehicle's owner registered as operator, with a valid operator card displayed (category G for goods vehicles over 3,500 kg GVM) | Copy of operator card per vehicle | On expiry |
| Vehicle licensing | Licence disc valid for every truck and trailer | Copy of licence disc or registration certificate | On expiry |
| Roadworthiness | Certificate of fitness or roadworthy valid where required | COF copy per vehicle | On expiry; spot check on site |
| Payload | Tare, GVM or GCM and permissible maximum payload per combination | Signed payload and load distribution statement (reg 330A) | Each new vehicle or configuration |
| Drivers | Correct licence code and a valid professional driving permit (PrDP) | Licence and PrDP copies per driver | On expiry; check every new driver |
| Driver fitness | Medical fitness and any client-specific requirements (induction, substance testing) | Certificates and induction records | As per client or site rules |
| Insurance | Vehicle, goods-in-transit and public liability cover suitable for your loads | Insurance schedule naming the insured vehicles | Annually and on renewal |
| Safety record | Incident history, traffic offences, previous client references | Signed declaration, references | Annually |
| Tracking | Vehicle tracked, with data you can access for your trips | Tracking provider confirmation, shared access | At onboarding |
| RTMS status | Certified or not; if certified, certificate number and expiry | RTMS certificate copy | On expiry |
| Agreement | Signed subcontract agreement with loading instructions and responsibilities | Agreement on file | On renewal or rate change |

For the driver documents in more detail, see our driver licensing and PrDP guide. For roadworthy and COF timing, see the COF guide for heavy vehicle operators.

How Do You Verify Documents Instead of Just Collecting Them?

A folder of photocopies is not vetting. Copies can be out of date, belong to a different vehicle, or be altered. Practical verification steps:

• Match registration numbers. Check that the operator card, licence disc, COF and insurance schedule all list the same registration and the same owner.
• Check the person, not just the permit. At the gate, compare the driver's licence card and PrDP with the person in the cab.
• Confirm insurance with the insurer or broker. A schedule shows cover on the day it was printed. A quick confirmation from the broker shows it is still in force.
• Confirm bank details by phone. Payment diversion fraud often targets sub-hauler payments. Verify any change of banking details on a number you already hold, never one supplied in the change request.
• Weigh the first loads. The payload statement is a promise. Weighbridge slips on the first few loads show whether it holds.

How Should You Monitor Subcontractors After Onboarding?

Vetting is not a once-off event. Documents expire, drivers change and a good sub-hauler can slide when work is short. Build these checks into the operation:

1. Dispatch checks on every load. Before a subcontracted vehicle is loaded, confirm it is on your approved vehicle list, the driver is on your approved driver list, documents are in date and the load is within the agreed payload. The RTMS templates include a dispatch and access authorisation log you can adapt.
2. Expiry tracking. Keep a register of every subcontractor document with its expiry date and warn the sub-hauler 30 days ahead. A lapsed COF should block dispatch, not trigger an apology afterwards.
3. Trip data. Ask for tracking access for your trips. Speed, route deviation and rest stops on your loads are legitimate operating data for the contract, provided the agreement covers it.
4. Incident and complaint log. Record every breakdown, delay, damage claim, traffic fine and client complaint against the subcontractor.
5. Periodic evaluation. Score each sub-hauler at least once a year on compliance, safety, service and paperwork. Under the RTMS standard, consignors evaluate non-certified transporters at least annually, and the same discipline works for operators who subcontract.

| Score area | Example measures |
|---|---|
| Compliance | Documents in date at every dispatch; weighbridge results within limits |
| Safety | Incidents, speeding events on your trips, traffic offences |
| Service | On-time loading and delivery, breakdown response |
| Administration | POD turnaround, invoice accuracy, response to queries |

What Should a Subcontract Agreement Cover?

Regulation 330C requires a written transport agreement covering loading instructions and each party's responsibilities. Beyond that minimum, a sound subcontract agreement usually covers:

• The vehicles and drivers approved to carry your loads, and the rule that substitutes need prior approval
• Loading instructions, maximum payloads and the obligation to refuse an overload
• Document and insurance requirements, with a duty to notify you of any lapse
• Responsibility for traffic fines, overloading fines and damage claims
• Site rules flowed down from your clients, such as speed limits, PPE and induction
• Tracking data access and the purpose it may be used for
• Proof of delivery, invoicing timelines and payment terms
• Your right to suspend or terminate for compliance failures

Have the agreement reviewed by a legal adviser. Fine and liability clauses do not override the law, and a clause that shifts all responsibility to the sub-hauler will not undo duties that the regulations place on a consignor or consignee.

How Can Software Help Manage Subcontractors?

Spreadsheets work for two or three sub-hauliers. Beyond that, expiry dates slip and dispatchers under pressure load the truck that is available. A fleet or transport system helps by holding subcontractor vehicles and drivers in the same register as your own, with documents and expiry dates attached, and by blocking dispatch when something has lapsed.

T-ERP can hold subcontracted vehicles in the fleet register alongside owned vehicles, track driver credentials and expiries, record weighbridge masses against each trip, and report on subcontractor compliance each month. See RTMS compliance for how the records fit together, or our transport operations overview. The driver credential management guide covers the driver side in more depth.

Conclusion

Transport subcontractor vetting protects your clients, your contracts and your own legal position. The consignor and consignee regulations make written agreements, accurate mass determination, goods declarations and insurance part of the law, not optional extras. A clear onboarding checklist, verified documents, dispatch checks on every load and an annual evaluation turn subcontracting from a risk you hope will not bite into a controlled part of your operation.

Start with the sub-hauliers you use most often, fix the gaps in their files, and make the checklist a condition of the next load. For background on the scheme itself, read RTMS explained.

Sources

• National Road Traffic Regulations, regulation 330A: offering and accepting goods (acts.co.za) - inserted by GN R. 846 of 2014 with effect from 31 January 2015
• Regulation 330B: consignor to have a method of determining mass (acts.co.za)
• Regulation 330C: goods declaration to be carried on a motor vehicle (acts.co.za)
• Regulation 330D: consignor or consignee to insure goods (acts.co.za)
• National Road Traffic Act, section 47: operator card to be displayed (acts.co.za)
• National Road Traffic Regulations, regulation 266: categories of operators (acts.co.za)
• RTMS standard SANS 1395 (RTMS-SA) - voluntary scheme; consignor and consignee requirements to verify certified transporters and monitor non-certified ones

The information in this article is for general guidance only. Regulations and requirements may change - always verify current requirements with the relevant South African regulatory authority.

Frequently Asked Questions

Am I responsible if my subcontractor's truck is overloaded?

It depends on your role in the load. The driver and operator remain responsible for the vehicle, but regulations 330A and 330B place duties on consignors and consignees not to offer, accept or contract for overloaded vehicles and to determine mass accurately. Clients will also hold you to your transport agreement. Get legal advice on a specific incident.

Do my subcontractors need to be RTMS certified?

RTMS is voluntary, so the law does not require it. Many clients do require it of their transporters and sometimes of sub-hauliers too. If you include subcontractor vehicles in your own RTMS scope, they must meet every requirement of the standard.

What documents should a sub-hauler's driver carry?

At minimum a valid driving licence of the correct code, a professional driving permit, and the goods declaration required by regulation 330C, which includes the transport agreement details and insurance schedule. The vehicle must display a valid licence disc and operator card.

How often should I re-vet a subcontractor?

Check expiring documents continuously, on or before their expiry dates, and confirm documents at dispatch for every load. Do a full re-vetting and performance evaluation at least once a year, and sooner after a serious incident or a change in ownership or banking details.

Can I make the subcontractor pay all fines and claims?

You can agree in writing who pays fines and damages between yourselves, and you should. That agreement does not remove duties the regulations place on you or your client, so it is not a substitute for vetting and dispatch checks.