Roofing is one of the more inconsistently regulated trades in construction. Some states license roofing contractors directly and run a criminal history check as part of that license. Other states fold roofing into a general contractor license. A few states do not license contractors at the state level at all, and leave registration to cities or counties. Anyone hiring a roofing contractor, running a roofing business, or staffing a roofing crew needs to know which category their state falls into, because the licensing rule and the hiring rule are two different things that both matter.
Licensing the business is not the same as screening the crew
A roofing contractor license is issued to the business or to the individual who qualifies the business, usually an owner or a designated qualifying party. The state licensing board reviews that person’s background, often including fingerprints, before issuing the license. That review does not extend to every laborer who shows up on a roof. Hiring a crew, whether as W2 employees or through subcontractors, is a separate decision that falls on the employer, and it is governed by the Fair Credit Reporting Act when the employer uses a third party to run the check, not by the state licensing board.
How roofing licensing varies by state
There is no single federal roofing license. Each state sets its own rule, and the rules are genuinely different in structure, not just in detail.
| State | State level roofing license | Fingerprint or criminal history review | Notes |
|---|---|---|---|
| Florida | Yes, Certified or Registered Roofing Contractor, issued by the Construction Industry Licensing Board within the Department of Business and Professional Regulation | Yes, fingerprints are required with most DBPR licensure applications | Certified license is valid statewide; registered license is tied to the local jurisdictions where the contractor is approved |
| California | Yes, the C-39 roofing classification under a Contractors State License Board license | Yes, license applicants submit fingerprints through Live Scan as part of the application | The license is issued to the business, with a qualifying individual who holds the exam-based qualification |
| Texas | No statewide license for roofing or general contracting | Not applicable at the state level | Texas Department of Licensing and Regulation licenses many trades but roofing and general contracting are not among them; some cities and counties run their own registration or permit rules, so check locally |
Florida: Certified and Registered Roofing Contractor
Florida’s Construction Industry Licensing Board defines a roofing contractor as a contractor whose services are unlimited in the roofing trade, covering installation, repair, replacement, and related work such as roof deck attachments and roof to wall connections. Florida issues both a Certified Roofing Contractor license, which is valid statewide, and a Registered Roofing Contractor license, which is tied to the local jurisdictions where the contractor has been approved to work. The Department of Business and Professional Regulation requires fingerprints with most of its licensure applications, submitted through an approved Livescan service provider, and the results are used as part of the department’s review of the applicant.
California: the C-39 classification
California licenses roofing contractors under the C-39 classification issued by the Contractors State License Board. The license is issued to the business, and the business must designate a qualifying individual who passes the required law and trade exams. As part of the licensing process, applicants submit fingerprints through Live Scan so the board can review criminal history before a license is issued. The board can also deny, suspend, or revoke a license based on conduct that violates the state’s contracting laws, separate from the fingerprint based review done at application.
Texas: no statewide roofing license
Texas is a clear example of a state with no statewide contractor license at all. The Texas Department of Licensing and Regulation licenses dozens of occupations, from electricians to barbers to auctioneers, but general contracting and roofing are not on that list. That means a roofing business can generally operate in Texas without a state issued contractor license or a state run background check tied to that license. It does not mean there is no oversight at all. Some Texas cities and counties maintain their own contractor registration or permitting requirements, so the rule can still vary by jurisdiction even where the state itself stays out of it.
Surety bonds and insurance
Where a state does license roofing contractors, the license is usually paired with financial requirements rather than relying on the background check alone. Most licensing states require proof of general liability insurance, and many require workers compensation coverage for any employees. A number of states and some local jurisdictions also require a surety bond, which gives a customer a path to recover money if the contractor fails to complete a job or pay a subcontractor. Bond amounts, insurance minimums, and whether workers compensation applies to owner operators all vary by state and by license classification, so a roofing contractor should confirm the current requirement with their own licensing board rather than assume a number from another state.
What the licensing board’s background review actually covers
When a state requires fingerprints for a contractor license, the results typically go through the state’s criminal history repository and, often, the FBI, and the board reviews any criminal history as part of deciding whether to issue the license. This is separate from, and happens earlier than, any background check an employer runs on a worker. A licensing board’s review also tends to focus on offenses related to fraud, theft, or conduct relevant to running a licensed trade business, and a conviction does not automatically bar someone from holding a license in every state. Applicants with a record should check their own state board’s specific disqualification rules rather than assume the worst case.
Screening the people who work on the roof
Separate from the business license, the employer still has to decide how to screen the crew, whether that is a foreman, a laborer, or a subcontractor’s employees working under the roofing company’s contract. A typical program for roofing crew hiring includes a criminal history review, verification of any required local trade registration, and a motor vehicle record check for anyone who will drive a company vehicle between job sites. If a vehicle meets the commercial motor vehicle definitions in the federal motor carrier safety regulations, drivers may be subject to additional licensing and testing rules under federal motor carrier safety regulations, including drug and alcohol testing, but most roofing crews driving pickup trucks and trailers below that threshold are not automatically covered just because they work in construction.
Drug testing on roofing job sites is common given the fall risk and the physical nature of the work, but it is a matter of employer policy and state law rather than a single nationwide rule, and marijuana and other drug laws vary enough by state that employers should build their policy around their own state’s current law rather than a one size fits all approach.
FCRA duties when the employer runs the check
Whenever a roofing company uses a third party consumer reporting agency to run a criminal history check, a motor vehicle record, or a drug test report on a job applicant or employee, the Fair Credit Reporting Act’s employer duties apply. Under the permissible purpose rules in 15 U.S.C. 1681b, the employer must provide a standalone written disclosure and get the applicant’s written authorization before ordering the report. If the employer is considering taking adverse action, meaning not hiring, not promoting, or terminating someone based in whole or in part on the report, the employer must send a pre-adverse action notice along with a copy of the report and a copy of the Summary of Rights, give the person a reasonable chance to respond, and then send an adverse action notice if the decision stands. A background check does not show the same things in every state. State law, and the general seven year reporting rule under the FCRA’s definitions in 16 CFR part 603, both affect what can appear on a report, so employers should not assume a record will or will not show up without checking their own state’s rules.
Putting licensing and hiring together
A roofing business owner should start with their own state licensing board to confirm whether a license is required, what the application involves, and whether fingerprints or a criminal history review are part of it. From there, hiring decisions for the crew are a separate process that should follow the same FCRA disclosure, authorization, and adverse action steps that apply to any other employer, along with an MVR check for drivers and a drug testing policy that fits state law. For a broader look at how these same duties apply outside roofing specifically, see our posts on electrician background check requirements and background checks for independent contractors. Reveal Background works with employers across the trades to build a screening program that fits their state’s rules; learn more at revealbackground.com.
Frequently asked questions
Do all states license roofing contractors?
No. Some states, like Florida and California, issue a specific state level license for roofing contractors. Other states have no statewide contractor license at all, like Texas, and leave any registration to local cities or counties. Where a state has no rule, it is accurate to say there is no statewide requirement rather than guess at one.
Does a roofing license application include a background check?
In states that require fingerprints with a contractor license application, such as Florida and California, the fingerprint results are used as part of the board’s review of the applicant, which functions as a criminal history check. In states without a state level license, there is no equivalent state run review.
Can a roofing contractor be denied a license for a criminal record?
A licensing board may be able to deny or discipline a license based on certain criminal history, particularly convictions related to fraud, theft, or conduct relevant to running a licensed business, but the specific disqualifying offenses and any review process vary by state board, and a record does not automatically disqualify every applicant in every state.
Do roofing companies have to run background checks on crew members?
There is no single federal law requiring every roofing employer to run a background check on every hire. Many roofing companies choose to screen crew members for safety and liability reasons, and once they use a third party reporting agency to do it, the FCRA’s disclosure, authorization, and adverse action rules apply.
Are roofing crews subject to DOT drug testing?
Only if the vehicles they drive meet the commercial motor vehicle thresholds under the federal motor carrier safety regulations. Most roofing crews driving standard pickup trucks and trailers fall below that threshold and are not automatically subject to DOT testing just because the company is in construction.
What does an employer have to do before taking adverse action based on a background check?
The employer must send a pre-adverse action notice with a copy of the consumer report and the Summary of Rights, give the applicant a reasonable opportunity to respond, and then send a final adverse action notice if the decision to not hire, or to take another adverse action, stands.
This article is general information, not legal advice. Licensing requirements and employment screening law vary by state and change over time, so confirm current rules with the relevant state licensing board or legal counsel before relying on them.
