Florida contractors often outgrow a single license category. A general contracting firm may want to add roofing capability, an electrical contractor may add another qualifier to expand capacity, or a company may bring on a new qualifier during a transition period. These are all legitimate business moves—but they create a compliance issue that can become expensive later if it’s handled informally:
When a Florida contracting business has more than one qualifier, who is “Primary,” who is “Secondary,” and who carries responsibility—especially for “financial matters” and overall supervision?
This article explains:
- why a company might have multiple qualifiers,
- what contractors commonly mean when they say “joint agreement,”
- how Primary vs. Secondary status changes responsibility,
- how the FRO concept fits in, and
- which DBPR forms are commonly used for CILB and ECLB scenarios (including the common “CILB 9 + designation form” filing approach).
Note: DBPR forms are periodically updated, renumbered, or revised. Always confirm you’re using the current version of the relevant form(s) directly from DBPR/your licensing board before submitting.
Why would a company have multiple qualifiers?
There are several common, legitimate reasons Florida contractors add a second (or third) qualifier.
1) Expanding into additional trades under one company
A company may want to offer a broader set of services under one business entity. For example:
- A general contracting firm wants to pull permits and contract for roofing under the same entity.
- A company wants in-house capability in a specialized scope rather than relying on subcontracting for licensing reasons.
- A contractor wants flexibility to bid work that effectively requires certain licensing coverage.
2) Continuity and transition planning
Sometimes a second qualifier is added because:
- the current qualifier is retiring or leaving,
- the company wants a “backup” to avoid a business interruption,
- or the company wants a transition period with overlap so there is no gap in qualifying status.
3) Scaling operations and supervision
As contractors scale, “one qualifier for everything” can become unrealistic. Additional qualifiers can help with:
- supervising multiple concurrent projects,
- geographic spread,
- jobsite oversight that is real and defensible (not just “on paper”).
4) Mergers, acquisitions, restructuring
When companies combine, it’s common for the surviving entity to maintain multiple qualifiers (temporarily or long-term), especially where different qualifiers hold different license categories or specialties.
The real issue: Primary vs. Secondary qualifiers (and why it matters)
When there’s more than one qualifier, the key risk is unclear status. If the company does not properly document Primary vs. Secondary roles, the board record can be ambiguous, and qualifiers may unintentionally take on broader responsibility than they expected.
Most businesses, when adding a trade qualifier, intend something like:
- “We want one person to remain the main overall qualifier (Primary),”
- “We want the added qualifier to be limited to the trade scope (Secondary).”
That intent needs to be properly documented so the regulatory record matches operational reality.
What contractors mean by a “joint agreement”
In Florida contractor licensing conversations, people often say “we need a joint agreement” when what they really mean is:
the board-required paperwork (on the board’s form) that designates one qualifier as the Primary (often the sole Primary) and designates the other(s) as Secondary—so responsibility is allocated clearly.
It’s not typically a free-form contract you draft on letterhead. It’s typically a DBPR/board form submission with required signatures that the board processes so the company’s file reflects the intended Primary/Secondary structure.
Where the FRO fits (and what it is not)
Another frequent point of confusion is financial responsibility.
Trade qualifier vs. “FRO”
A qualifier for roofing, HVAC, or another trade does not automatically become a Financially Responsible Officer (FRO) just because they were added to the license. “FRO” is a separate designation (where applicable).
Why Primary/Secondary status still matters
Even if someone is not the FRO, Primary vs. Secondary status can still matter because “Primary” status is generally associated with broader, company-level responsibility and oversight expectations. When a company intends for an added trade qualifier to have a narrower role, it is usually best practice to document that qualifier as Secondary.
Common scenarios and best-practice structure
Scenario A: GC company adds a roofing qualifier
Goal: Expand services; keep one overall “main” qualifier.
Best practice: Keep the existing qualifier as Primary and document the roofing qualifier as Secondary, with responsibility tied to the roofing scope where that license is used.
Scenario B: Company adds a second qualifier as a backup
Goal: Continuity and realistic supervision.
Best practice: Choose one sole Primary and make the other qualifier Secondary, and document responsibilities internally so everyone understands who supervises what.
Scenario C: Qualifier replacement overlap
Goal: Avoid a gap while transitioning to a new qualifier.
Best practice: File the change(s) promptly so the board record reflects the current structure throughout the overlap period.
Paperwork and forms: CILB vs. ECLB
Because different boards regulate different license categories, the paperwork differs.
For CILB (Construction Industry Licensing Board): adding a qualifier vs. designating Secondary status
For many CILB license categories, contractors commonly use:
- CILB 9 to add/qualify the additional qualifier to the business organization (this is often the “add the qualifier” step), and
- a separate CILB “change of status / Primary–Secondary designation” form to implement the Primary/Secondary structure (this is what people often mean by the “joint agreement paperwork”).
A form frequently used for that Primary/Secondary designation under CILB is commonly referenced as:
- CILB 24 – Request for Change of Status for Qualifying Agent(s) (commonly used to document Primary ↔ Secondary changes and keep the company’s record consistent with its intended structure).
Again, always confirm the current form number/title on DBPR’s site at the time of filing.
Can you designate the new qualifier as “Secondary” on CILB 9?
This is a common question, and it matters.
In practice, CILB 9 is typically the form used to add/qualify the additional qualifying agent, but it is not usually the form that formally establishes the Primary vs. Secondary structure by itself. If the company already has a Primary qualifier and the intent is that the newly added qualifier be Secondary, the safest and most common approach is a two-form submission:
- CILB 9 (to add/qualify the additional qualifying agent to the business), and
- the CILB Primary/Secondary change-of-status designation form (commonly referenced as CILB 24), signed as required and submitted so the board record clearly reflects that the new qualifier is Secondary and identifies who remains the Primary.
Why this matters: Without the proper Primary/Secondary designation filing, the company can create unnecessary ambiguity about who is “Primary,” which can increase exposure and complicate supervision and compliance expectations later. Submitting the designation paperwork together with the “add qualifier” paperwork is the best way to keep the file clean “from day one.”
For ECLB (Electrical Contractors’ Licensing Board): Primary/Secondary designation
Electrical licensing is handled under a different board with different forms. A commonly used form for Primary/Secondary designation is frequently referenced as:
- ECLB 5 – Designation of Primary and Secondary Qualifying Agents (used to document which qualifier is Primary and which is Secondary).
As with CILB, the practical goal is to ensure the board record matches what the company intends: one Primary (or a clearly defined Primary structure) and any additional qualifiers documented appropriately as Secondary.
Best practices when your company has multiple qualifiers
1) Make the board record match real operations
If the company intends one Primary and one Secondary, your filings should reflect that clearly.
2) Track permits and scopes by license
If a Secondary qualifier’s responsibility is tied to work where their license is used, the company should be able to show:
- which permits were pulled under which license,
- and which projects fall under the Secondary qualifier’s trade scope.
3) Put supervision expectations in writing
In addition to board filings, consider documenting internally (and often contractually through a qualifier agreement) items like:
- inspection cadence and documentation,
- permitting control,
- change order oversight,
- communication and reporting expectations,
- authority limits (who can bind the company),
- and what work the Secondary qualifier does—and does not—accept responsibility for.
4) Handle transitions immediately
Overlap periods are where mistakes happen. If someone changes status, departs, or shifts responsibilities, update filings promptly.
5) Don’t assume “Secondary” equals “no risk”
Secondary designation typically narrows responsibility, but real-world exposure can still arise depending on:
- what was actually supervised,
- what was permitted under that license,
- and what representations were made to third parties.
Bottom line
Operating with multiple qualifiers is common in Florida and can be a smart growth strategy. The danger is not “multiple qualifiers”—the danger is unclear structure. If your business adds a qualifier (especially to expand into roofing, electrical, or other specialized scopes), the cleanest approach is usually:
- file the “add qualifier” paperwork (often CILB 9 in CILB contexts), and
- file the Primary/Secondary designation paperwork (often referenced as CILB 24 for CILB, or ECLB 5 for electrical) so the record clearly shows who is Primary and who is Secondary.
That keeps your licensing file consistent with how the company actually operates and reduces avoidable disputes about responsibility later.