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The debates on the use of subcontracting as a tool of using ununionized labor force have not been ended after the Labor Law had been put into force. In contrast, the concepts of “the requirements of enterprise or work and technology- required specialization” that take place in new Labor Law have led to new debates. While some authors take such concepts as a whole, some writers interpret such concepts either in the context of enterprise-requirement or work requirement. In this paper, a different evaluation of “enterprise requirement,” “work requirement” or “technological specialization” will be provided. The definition and classification of sub-contracting of UNIDO will be first evaluated, then the subcontracting of some of the work being sub-contracted by the contractor to the subcontractor will be critically and thoroughly examined. In conclusion section, whether the sub-contractor is an independent employer will be first critically examined and then suggestions on the topic will be provided.