The short answer
Under the Control of Asbestos Regulations 2012, asbestos work falls into one of three categories:
- Licensed work: higher-risk work that must be done by a contractor holding an HSE licence.
- Notifiable non-licensed work (NNLW): lower-risk work that doesn’t need a licence, but must be notified before it starts, with medicals and records.
- Non-licensed work: lower-risk work with no notification, but still with a risk assessment, trained workers and proper controls.
Which category applies depends on the material, its condition and what is being done to it. It’s decided by the risk assessment, not by the customer or the price.
Licensed work
HSE says “most higher-risk work with asbestos must only be done by a licensed contractor”. HSE’s licensable work page gives examples including:
- removing sprayed coatings (limpet asbestos)
- any work involving loose-fill insulation
- work on asbestos millboard
- most work that disturbs pipe lagging
- most work on asbestos insulating board (AIB) that isn’t short-duration
The law also makes work licensable where exposure is not “sporadic and of low intensity”, or where the risk assessment can’t clearly show the control limit won’t be exceeded (regulation 2).
Licensed work must be notified to the enforcing authority on the ASB5 form at least 14 days before it starts, unless the authority agrees a shorter time. Workers must have a medical at least every two years. After licensed removal, an independent UKAS-accredited analyst carries out four-stage clearance and issues a certificate for reoccupation. See air testing and clearance.
Notifiable non-licensed work (NNLW)
NNLW is work that doesn’t need a licence but carries extra duties. HSE’s page on notifiable non-licensed work (NNLW) gives examples:
- removing asbestos cement that will be substantially damaged or broken up, for example after a fire or flood
- removing asbestos paper and cardboard that isn’t firmly bonded in a matrix
- short-duration removal of AIB as part of a refurbishment project
- repairing minor damage to a small section of pipe insulation where the outer coating is broken
- large-scale removal of textured coatings such as Artex using steaming or gelling methods
For NNLW the employer must:
- notify the enforcing authority before work starts. There is no minimum notice period, and the online form is the only way to notify
- arrange medicals, repeated at least every three years while the worker carries on with NNLW, including a chest examination and lung function test
- keep registers of work (health records) for 40 years
- designate the work areas
Non-licensed work
HSE’s non-licensed work page says work is non-licensed when it is sporadic and of low intensity (no more than 0.6 fibres per cm³ measured over 10 minutes), exposure stays below the control limit, and the task fits one of four types set out in regulation 3(2): short maintenance on non-friable materials, careful removal of well-bonded materials that are not degraded, encapsulating or sealing materials in good condition, and air monitoring or sampling.
HSE examples include:
- removing asbestos cement handled carefully without breaking it up, such as most garage roofs
- maintenance of asbestos cement roofing, gutters and tiles
- work on vinyl floor tiles, bitumen felt and mastics
- drilling textured coatings to fit fixtures
- minor repairs to AIB, or drilling small holes in it
- encapsulating or sealing materials in good condition
- collecting samples
Non-licensed doesn’t mean unregulated. The employer still needs a risk assessment, a written plan of work, trained workers, suitable RPE, controls to keep exposure as low as reasonably practicable, and correct waste handling.
The control limit
The control limit is 0.1 fibres per cm³ of air averaged over a continuous four-hour period. HSE is clear that “the control limit is not a ‘safe’ level”. Employers must keep exposure as low as reasonably practicable, well below it where they can. In May 2026 HSE decided not to change the GB limit.
Who decides which category applies?
The employer doing the work decides, through its risk assessment, before work starts. It must identify the material, its type and condition, and what the job involves. If in doubt, the law says to assume asbestos is present and that it isn’t white asbestos alone (regulation 5).
HSE’s HSE’s Asbestos essentials introduction (A0) has a decision flowchart on page 7. It asks about the material, its condition, what the work is and how long it lasts, and leads to one of three outcomes: needs an HSE-licensed contractor, notifiable non-licensed, or non-licensed. It’s the clearest single picture of how the system works.
The same material can fall into different categories depending on the job. A garage roof removed sheet by sheet is normally non-licensed. The same roof after a fire, broken into pieces, can be NNLW. Some AIB work can be done in short bursts as NNLW, but most AIB work needs a licence.
Common mistakes
- “All Artex needs a licensed contractor.” Wrong. HSE guidance says textured coatings work is not normally licensable. Large-scale steam or gel removal is NNLW.
- “Asbestos insulating board is non-licensed.” Mostly wrong. Most work on AIB is licensable.
- “Asbestos cement work is never notifiable.” It can be, if the cement will be substantially broken up.
- “NNLW needs 14 days’ notice.” No. That is licensed work. NNLW is notified before work starts, with no minimum period.
- “Medicals every year.” The law says at least every two years for licensed work and at least every three years for NNLW.
How to check an HSE licence
If a job needs a licence, ask the contractor for its licence details and check them against the list of current licence holders: HSE’s licensable work page links to it under “Find a licensed asbestos contractor”. Licences are granted for up to three years at a time (regulation 8), so check the current one.
Licensed removal must be done by a contractor holding an HSE licence. Our licensed removal page explains the process, and our contractor checklist covers what else to ask.
Quick answers
Is garage roof removal licensed?
Normally not. Careful removal of cement sheets without breaking them is non-licensed work. If the sheets will be substantially broken up, it is NNLW.
Is Artex removal licensed?
Not normally. Small-scale work is non-licensed. Large-scale removal by steaming or gelling is NNLW.
Does a homeowner have to notify anyone?
Notification is a duty on employers doing the work. If you employ a contractor, it is their job to notify where the work requires it.
Where is the HSE flowchart?
On page 7 of HSE’s Asbestos essentials introduction (A0).
This guide is general information, not legal advice. For the law itself, see the Control of Asbestos Regulations 2012 and HSE’s asbestos pages. Not sure what you’re dealing with? Ask us.