A prime contractor's DBA obligation is straightforward for its own employees. The complication is the subcontract chain.
Why primes carry exposure
When a subcontractor fails to carry required DBA coverage, the obligation to injured employees does not simply disappear. Depending on the contract structure and circumstances, exposure can flow upward — meaning a prime can end up carrying costs for personnel it never employed and never priced.
Where gaps appear
- Lower-tier subcontractors who did not receive or did not understand flow-down requirements
- Small subcontractors on their first overseas contract
- Locally hired staff whom a subcontractor assumed were out of scope
- Certificates that lapse mid-contract without anyone tracking renewal
- Coverage that does not extend to a country added after the original placement
Practical controls
Require certificates before mobilization, not after. Track expiration dates centrally. Re-verify when scope changes or new countries are added. Confirm that flow-down language actually reached every tier rather than stopping at the first.
None of this is complicated, but it does require someone to own it. On contracts with several subcontract tiers, that ownership is worth assigning explicitly.