Michigan HVAC Qualifying Officer (Contractor of Record) Requirements — What Every Contractor Needs to Know

The Person Behind Every Michigan Mechanical Contractor License

Michigan's mechanical licensing rules do not use the term "Qualifying Officer" for this role. Under the Skilled Trades Regulation Act (PA 407 of 2016), a person or other entity performing covered work must designate the holder of a Mechanical Contractor license as its contractor of record and notify the department in writing. Contractors and search results sometimes call this person a QO, but "contractor of record" is the statutory term.

This distinction matters because the business can only perform work within the classifications that the contractor of record carries. If that person is licensed for Classification B (HVAC Equipment) and Classification C (Ductwork) but not Classification D (Refrigeration), the company cannot legally contract for refrigeration work. The contractor of record's credentials define the company's scope.

What the Contractor of Record Must Have

To serve as the contractor of record for a Michigan mechanical contracting business, the individual must meet all of the following:

• Three years (6,000 hours) of documented field experience for each classification they want on the license, verified through employer statements signed under penalty of perjury and submitted to LARA
• A passing score on the PSI examination for each requested classification (70-75% depending on the exam)
• Active involvement in the business — a QO who isn't genuinely participating in the company's operations is considered a "paper qualifier," and LARA treats this as licensing fraud
• A current Mechanical Contractor license — LARA's renewal guidance says this license renews every three years and does not require code-update courses

The contractor of record's license is the credential tied to the company's permitted scope. If the business pulls permits using that license and the work fails inspection or violates code, the license holder and the business may both face LARA disciplinary action.

How the Business Designates Its Contractor of Record

The standard structure is one designated contractor of record per Mechanical Contractor license. A sole proprietor is typically its own contractor of record. An LLC or corporation designates an employee or officer who holds a Mechanical Contractor license.

An LLC or corporation must notify the department in writing of its contractor-of-record designation. The designation ties the business's permitted work to the license holder's classifications.

If a business needs more classifications than its contractor of record carries, add classifications to that individual's license; each requested classification has its own experience and examination requirements.

What Happens When Your Contractor of Record Leaves

This is the scenario that catches businesses off guard. If the contractor of record ceases to be an employee or officer, MCL 339.5815 gives the business 90 days to designate an employee or officer who holds a Mechanical Contractor license as the new contractor of record and notify LARA in writing. If the individual contractor of record ceases to do business as a mechanical contractor and sells the business interest, the buyer has 90 days to make the designation.

The replacement must already hold a Mechanical Contractor license; the 90-day period is for making the designation and notifying LARA, not for bypassing the licensing requirement.

Businesses should identify a licensed replacement before the 90-day period expires, because the statute requires the new designee to be an employee or officer who holds a Mechanical Contractor license.

The Licensing Path to Becoming a QO

Becoming the contractor of record uses the individual's Mechanical Contractor license; it is not a separate QO license. You apply through LARA, document your experience, pass the PSI exam, and have the business designate you as its contractor of record in writing.

The Michigan HVAC License Guide walks through the full QO pathway: experience documentation, exam logistics, business entity registration, and the ongoing compliance requirements that keep the license active.

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