Do I Need to Use a Licensed Asbestos Removal Contractor?

Hotel managers and project leads are often told they must use a licensed asbestos removal contractor whenever asbestos is involved. Others are advised that some works can be completed without a licence. With conflicting advice from contractors and tight project timelines, it’s difficult to know what’s actually required.

So when is a licensed asbestos contractor mandatory and when is it not?

The Legal Reality

Under the Control of Asbestos Regulations 2012, asbestos work is categorised into three distinct types:

• Licensed work

• Notifiable non-licensed work (NNLW)

• Non-licensed work

Whether a licence is required depends on the type of asbestos, its condition, and how it will be disturbed, not simply the presence of asbestos.

Licensed asbestos work

You must use a licensed asbestos removal contractor when working with higher-risk asbestos materials, including:

• Pipe insulation

• Asbestos insulating board (AIB) in poor condition

• Loose fill asbestos

• Any work that is likely to generate significant fibre release

This work must be notified to the HSE and carried out under strict controls by a contractor holding a valid asbestos licence.

Notifiable non-licensed work (NNLW)

Some lower-risk asbestos materials do not require a licence but must still be notified and managed carefully. This includes certain removal or repair works where asbestos is disturbed but remains low risk if controlled correctly.

Non-licensed work

Very limited, low-risk tasks such as short-duration work on asbestos cement in good condition may be carried out without a licence, provided workers are trained, competent, and appropriate controls are in place.

The Risk of Getting It Wrong

Incorrectly categorising asbestos work is one of the most common compliance failures in hotels.

If licensed work is carried out by a non-licensed contractor, the dutyholder remains legally responsible. Consequences can include:

• HSE enforcement action

• Project shutdowns

• Costly remediation

• Reputational damage

This is why relying solely on contractor advice can be risky. Contractors are experts in removal, not in determining your legal responsibilities as a dutyholder.

The Consultant’s Role

At The KV Group, we assess asbestos risks before work begins and determine:

• Whether work is licensed, notifiable, or non-licensed

• What level of contractor competence is required

• What notifications, controls, and documentation are needed

We then coordinate with the appropriate licensed asbestos contractors, analysts, and project teams, ensuring compliance without unnecessary cost or disruption.

Final Word

You do not always need a licensed asbestos removal contractor, but when you do, it is not optional.

The key is understanding what type of work you are undertaking, not just what material is present. Getting this decision right protects your people, your project, and your legal position.

Independent advice should always come before contractor appointment. Not sure whether your project requires a licensed contractor? Then speak to an independent asbestos consultant before work begins.

Learn more about asbestos compliance for hotels, or

Speak with The KV Group for impartial advice.

The KV Group stands for impartiality and expertise in asbestos management, giving clients reassurance and financial control over compliance.

Frequently Asked Questions

Is a licensed asbestos contractor always required?
No. Only higher-risk asbestos work requires a licence. Lower-risk work may fall under notifiable or non-licensed categories.

Who decides whether work is licensed?
The dutyholder is legally responsible, but this decision should be informed by an independent asbestos consultant, not the contractor carrying out the work.

What happens if licensed work is done without a licence?
This is a serious breach of the Control of Asbestos Regulations 2012 and can lead to enforcement action and prosecution.

Can hotel maintenance teams remove asbestos themselves?
Legally, yes- but only for very limited non-licensed asbestos work. In practice, hotel maintenance teams are rarely insured or suitably trained to carry out asbestos removal, even where the work is technically non-licensed. Without appropriate training, controls, risk assessments, and insurance cover, removal should not be undertaken.

Do I need air testing after asbestos removal?
Licensed work requires independent air testing and clearance by a UKAS-accredited analyst before reoccupation.