Coordination of business activities (CAE)

What is business activity coordination?

Article 24 of Law 31/1995 establishes that when workers from two or more companies carry out activities at the same workplace, these companies must cooperate in the application of prevention regulations, establishing the necessary means of coordination for the protection against occupational risks and the dissemination of information about them. Royal Decree 171/2004 develops this article and defines the three scenarios of concurrence: companies that simply share a workplace, a principal employer who has workers at the workplace, and contractors or subcontractors who perform works or services related to the principal employer’s own activity.

Each scenario adds obligations to those of the previous one. All participating companies must cooperate and inform each other of the specific risks of their activities that may affect others, both before starting work and in the event of changes or emergencies. The main contractor must also inform all parties involved of the site’s own risks and provide written instructions for their prevention when the risks are serious or very serious. The main contractor must monitor compliance with regulations by contractors and subcontractors and require them to provide written proof of risk assessment, preventive planning, and training and information for their workers.

The CAE (Competition Assessment) is not a mere paperwork formality, although in practice it has often been reduced to simply exchanging certificates. The INSST (National Institute for Safety and Health at Work) insists in its 2024 guidelines that the purpose is the effective control of risks arising from shared work, and that generic documents that do not describe the actual risks of shared work do not fulfill the obligation.

Differences between CAE, subcontracting and construction-site coordination

The coordination of activities is confused with other figures that regulate the relationship between companies.

• Coordination of business activities. Preventive obligations when several companies are present at a workplace, regardless of the contractual relationship between them. This is regulated in Article 24 of the LPRL (Law on Prevention of Occupational Risks) and Royal Decree 171/2004.
• Subcontracting in construction. The regime of Law 32/2006 limits the levels of subcontracting and requires the subcontracting book and the registration of accredited companies; it is an additional sectoral regulation to the CAE.
• Coordination in construction projects. In projects with a design, the required environmental impact assessment (EIA) is fulfilled through the roles established in Royal Decree 1627/1997: health and safety coordinator , health and safety study and plan. The first additional provision of Royal Decree 171/2004 expressly establishes this.

Practical rule: CAE applies whenever there is physical concurrence in a center, with or without a contract between the companies; subcontracting and work coordination are specific regimes that are added in the construction sector.

How coordination is managed in practice

The management of workplace safety begins by identifying who is involved, where, when, and with what risks, and by deciding what coordination measures are appropriate to the hazards and complexity of the activities. Royal Decree 171/2004 lists, but is not exhaustive, the following means: information exchange, regular meetings, joint committee meetings, instructions, the presence of preventive resources, and the designation of individuals responsible for coordination.

A typical procedure follows these steps:

1. Identify the concurrence scenario (simple concurrence, owner entrepreneur or main entrepreneur) and the associated obligations.
2. Exchange information on specific risks and on the risks of the center, in a sufficient and appropriate manner, before the start of the work.
3. Where appropriate, provide written instructions and require contractors and subcontractors to provide proof of their assessment, planning and training related to the work they are to perform.
4. Establish the means of coordination provided: meetings, work permits, presence of preventive resources or designation of a coordinating person when dangerous or especially complex activities occur.
5. Communicate the information and instructions to the workers of each company and their representatives.
6. Monitor compliance during execution, record checks, and update coordination in the event of changes, incidents, or emergencies.

The documentation must be specific to the concurrent work: a generic contractor assessment that doesn’t mention the site or the task is invalid. Document management platforms help control the validity of documentation, but they don’t replace on-site operational coordination.

Concurrent activities and the obligations of each party

Royal Decree 171/2004 distinguishes three cumulative situations:

• Companies sharing a premises. All those sharing a premises must cooperate, inform each other about specific risks, report accidents and emergencies, and take into account the information received in their own assessment and planning.
• Owner. The person who manages and controls the center must also inform about the center’s own risks, prevention measures and emergency procedures, and give appropriate instructions; in writing when the risks are serious or very serious.
• Main employer. Anyone who contracts works or services related to their own activity at their center must monitor compliance with regulations by contractors and subcontractors and require them in writing to provide accreditation of risk assessment, planning, training, and information for their workers, as well as verify that they have established means of coordination between them.
• Self-employed workers. They are obliged to cooperate and inform and are recipients of the information and instructions of the owner; the main must also monitor their compliance when they carry out works or services of the activity itself.
• Person in charge of coordination. Preferred method when hazardous or especially complex activities are involved; must have at least intermediate-level preventive training.

The main employer’s responsibility for Social Security and infringements may be joint and several with respect to its contractors under the terms of the Workers’ Statute and the Law on Infringements and Sanctions in the Social Order, which reinforces the importance of effective monitoring.

Common mistakes and effectiveness criteria

The most common deficiencies in the coordination of activities are:

1. Reducing CAE to an exchange of generic documents without analysis of the risks of real concurrency.
2. Not informing contractors of the risks of the center and of emergency measures, or doing so only verbally when the law requires it in writing.
3. Accepting assessments and plans that do not refer to the specific work to be done at the center.
4. Failure to designate a preventive resource or coordinating person when concurrent activities require it.
5. Do not communicate the information to the workers who perform the task or to their representatives.
6. Forgetting to coordinate with self-employed workers, auxiliary service companies and technical visits.

Effective coordination is recognized because the people working at the center are aware of the risks of other companies, instructions reach those who perform the task, and there are recorded checks that the measures are applied.

Regulatory framework in Spain

• Law 31/1995, article 24. Establishes the obligations of cooperation, information and instruction between competing companies and the duty of supervision of the main employer; the joint and several liability of the main employer with the contractors and subcontractors of his own activity, for the preventive obligations during the period of the contract and when the infringement occurs in his workplace, is regulated in article 42.3 of the LISOS (Royal Legislative Decree 5/2000).
• Royal Decree 171/2004 . Develops article 24: defines the cases of concurrence, the duty of cooperation, the obligations of the owner and the principal, the means of coordination and the figure of the person in charge of coordination.
• Royal Decree 1627/1997 . In construction works, coordination is carried out through the health and safety coordinator and the health and safety plan, according to the first additional provision of Royal Decree 171/2004.
• Guidelines for effective coordination of business activities (INSST, 2024) . Technical criteria to ensure that coordination is proportionate to the hazards of the activities and is not limited to formal compliance.

A draft bill to amend Law 31/1995 is currently under consideration in 2026 and could affect aspects of coordination; it is advisable to review its status before finalizing any changes. In Latin America, contractor management is regulated within each country’s occupational health and safety management system, with specific obligations for the contracting company.