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Treat it as a recurring verification routine, not a clause in the contract. Decide who owns it, fix a short list of evidence the contractor produces each cycle, check that the people on site match the people on the records, and hold your own records rather than only the contractor's. What applies to your arrangement differs by state and by law, so confirm it with a qualified advisor.
Because a contract allocates cost and recourse between two businesses, and certain duties attach to the organisation where the work is performed regardless of what the two businesses agreed. An indemnity is worth having and does not change who the authority deals with, nor does it help much when the contractor that owes you the indemnity is the one in difficulty. Read the clause as what you can recover afterwards rather than as protection from the duty itself, and establish which duties actually sit with you, in your arrangement and your state, with a qualified advisor rather than inferring it from the agreement.
A short list you genuinely check beats a long one you file. Which documents belong on it depends on the regime that applies to your engagement, so build the list with an advisor once and then keep it stable, because stability is what makes an absence visible. The important discipline is the record of receipt: what arrived, for which period, covering which people, and what was missing. A folder of documents proves that somebody collected paperwork. A dated log of what was requested, received and chased proves that somebody was checking, and those are very different things when the question is asked later.
By comparing them with something the contractor did not produce. Access control logs, the gate register, the site supervisor's own list or induction records all come from a different source, and reconciling any of them against the contractor's deployment record is the check that finds the real problems: people working who are not on any record, people on the record who left, and names that differ between systems. Doing it occasionally and unannounced is more informative than doing it thoroughly and on a schedule everybody knows. The point is not to catch anyone out but to establish whether the paperwork describes the site.
One named person per engagement, with a deputy, and the answer is usually not procurement alone. Procurement owns the commercial relationship and is measured on cost and delivery, so a compliance gap arrives as an obstacle to a payment rather than as its own issue. Human resources understands the obligations but often has no visibility of the supplier relationship or the invoice. Site operations knows who is actually there and is not asked. Whichever function holds it, write down who checks what and who is told when something is missing, because the reliable failure pattern here is an obligation every function believes another one has.
Treat it as a live issue with a date on it rather than as chasing. Record what is outstanding, for which period and which workers, tell someone with authority over the relationship, and decide explicitly whether work continues while it is unresolved. Continuing is often the right commercial answer and should be a decision somebody made, not a default that happened. A pattern of missing evidence usually indicates a supplier under financial strain, which is exactly the situation in which the exposure to the principal employer is highest, so a second consecutive gap deserves a different response from the first.
As a population you can see. Workers who are not on payroll are invisible to reports keyed to payroll, so headcount, access reviews and capacity planning all describe a smaller organisation than the one operating. Holding these people as a distinct class, with their contractor, site, engagement dates and evidence status, in the same place as your employee records rather than in a procurement folder is what allows a straightforward question about who works here to have a straightforward answer. Keeping them distinct from employees matters as much as recording them, because merging the two populations creates a different problem.
Potentially the applicability tests, the registrations, the records and the authority you deal with, so a new location is a fresh question rather than a copy of the last answer. The same is true of changes that feel purely operational: extending a contractor's scope, engaging a second contractor at one site, or a seasonal increase in deployed workers can move an engagement across a line that nothing internal records. Attach the compliance question to the decision that triggers it, so it gets asked by whoever approves the change and answered before the arrangement starts rather than during a review.
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